U.S. Postal Service: Mail-Related Recycling Initiatives and	 
Possible Opportunities for Improvement (03-JUN-08, GAO-08-599).  
                                                                 
In 2006, the U.S. Postal Service (USPS) discarded about 317,000  
tons of undeliverable-as-addressed advertising mail. Such mail	 
can be disposed of using incineration, landfills or through other
methods. USPS recently committed to minimizing the agency's	 
impact on every aspect of the environment. Recycling		 
undeliverable advertising mail can help USPS achieve this	 
commitment, while generating revenue and reducing its costs and  
financial pressures. In response to the 2006 Postal		 
Accountability and Enhancement Act, this report addresses (1)	 
recent mail-related recycling accomplishments (initiatives)	 
undertaken by USPS, the mailing industry, and others and (2)	 
additional recycling opportunities that USPS could choose to	 
engage in, or influence mailers to undertake. To conduct this	 
study, GAO analyzed relevant data and documents, visited USPS and
other facilities, and interviewed about 40 stakeholders.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-599 					        
    ACCNO:   A82241						        
  TITLE:     U.S. Postal Service: Mail-Related Recycling Initiatives  
and Possible Opportunities for Improvement			 
     DATE:   06/03/2008 
  SUBJECT:   Agency missions					 
	     Cost accounting					 
	     Cost analysis					 
	     Cost control					 
	     Cost effectiveness analysis			 
	     Data collection					 
	     Data integrity					 
	     Environmental monitoring				 
	     Environmental policies				 
	     Environmental protection				 
	     Financial analysis 				 
	     Financial management				 
	     Lessons learned					 
	     Mail delivery problems				 
	     Mission essential operations			 
	     Policy evaluation					 
	     Postal service					 
	     Program management 				 
	     Recycling						 
	     Strategic planning 				 
	     Waste disposal					 
	     Waste management					 
	     Cost estimates					 
	     Pilot programs					 
	     program goals or objectives			 
	     Program implementation				 

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GAO-08-599


This is the accessible text file for GAO report number GAO-08-599 
entitled 'U.S. Postal Service: Mail-Related Recycling Initiatives and 
Possible Opportunities for Improvement' which was released on June 3, 
2008.

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Report to Congressional Committees: 

United States Government Accountability Office: 
GAO: 

June 2008: 

U.S. Postal Service: 

Mail-Related Recycling Initiatives and Possible Opportunities for 
Improvement: 

GAO-08-599: 

GAO Highlights: 

Highlights of GAO-08-599, a report to congressional committees. 

Why GAO Did This Study: 

In 2006, the U.S. Postal Service (USPS) discarded about 317,000 tons of 
undeliverable-as-addressed advertising mail. Such mail can be disposed 
of using incineration, landfills or through other methods. USPS 
recently committed to minimizing the agencyï¿½s impact on every aspect of 
the environment. Recycling undeliverable advertising mail can help USPS 
achieve this commitment, while generating revenue and reducing its 
costs and financial pressures. 

In response to the 2006 Postal Accountability and Enhancement Act, this 
report addresses (1) recent mail-related recycling accomplishments 
(initiatives) undertaken by USPS, the mailing industry, and others and 
(2) additional recycling opportunities that USPS could choose to engage 
in, or influence mailers to undertake. To conduct this study, GAO 
analyzed relevant data and documents, visited USPS and other 
facilities, and interviewed about 40 stakeholders. 

What GAO Found: 

USPS and the mailing industry have undertaken numerous initiatives to 
increase (1) the recycling of mail-related materials and (2) the amount 
of mail with environmentally preferable attributes, such as mail that 
uses recycled paper. USPS has five key recycling-related initiatives 
underway. For example, USPS recently established annual goals to 
increase its revenue from mail-related recycling from $7.5 million to 
$40 million from fiscal years 2007 to 2010. However, by excluding 
savings that result from lower waste disposal costsï¿½which accompany 
increased recyclingï¿½the goals do not reflect the full financial benefit 
attributable to mail-related recycling. USPS also has launched a pilot 
recycling program in New York City, but it is not known whether USPS 
will require its managers elsewhere to adopt applicable ï¿½lessons 
learnedï¿½ from the pilot. Representatives of the mailing industry and 
other stakeholders also have undertaken a wide range of initiatives to, 
among other actions, increase the amount of mail that is recycled. For 
example, three mailing industry associations recently introduced 
separate awareness campaigns to encourage mail recipients to recycle 
their catalogs, envelopes, and magazines. In addition, the Direct 
Marketing Associationï¿½whose members collectively send about 80 percent 
of all Standard Mailï¿½is undertaking several initiatives, including an 
effort to encourage mailers to use environmentally preferable mail 
attributes. 

USPS, mailing industry, and other stakeholders GAO interviewed 
identified five opportunities that USPS could choose to undertake to 
increase its recycling of mail-related materials and to encourage 
mailers to increase the amount of mail with environmentally preferable 
attributes. The five opportunities stakeholders cited most frequently 
were for USPS to: (1) implement a program for recognizing mail-related 
recycling achievements; (2) increase awareness among mail recipients 
that mail is recyclable and encourage them to recycle their mail; (3) 
collaborate with parties interested in increasing the supply of paper 
fiber available for recycling; (4) establish a special, discounted 
postal rateï¿½or ï¿½Green Rateï¿½ï¿½as a means of inducing mailers to adopt 
environmentally preferable attributes; and, (5) initiate a ï¿½mail take-
backï¿½ program in locations that do not have access to municipal paper 
recycling. Each of these opportunities appears to be consistent with 
the agencyï¿½s long-standing commitment to environmental leadership and 
the Postmaster Generalï¿½s recent commitments to minimize the agencyï¿½s 
impact on every aspect of the environment and to act as a positive 
environmental influence in U.S. communities. Based on GAOï¿½s analysis, 
however, USPS would need to assess several factors including cost, 
feasibility (including logistical considerations), and mission 
compatibility in deciding whether to adopt these opportunities. For 
example, depending on the magnitude of variance between the expected 
costs and revenues, USPS may find implementing one or more of the 
opportunities unacceptable. This is, in part, because USPS faces 
multiple short- and long-term pressures in improving its operational 
efficiency, increasing its revenues, and controlling its costsï¿½some of 
which are increasing faster than the overall inflation rate. 

What GAO Recommends: 

GAO recommends, among other actions, that USPS (1) require managers at 
other facilities to adopt applicable lessons learned from its New York 
City recycling pilot and (2) adopt the opportunities identified in this 
report that are feasible, compatible with USPSï¿½ mission, and 
appropriate in view of cost and other considerations. USPS agreed with 
three of GAOï¿½s recommendations and stated that it is acting to 
implement them. USPS also agreed, in principle, with the remaining 
recommendation to adopt lessons learned from its pilot. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-599]. For more 
information, contact Katherine Siggerud at (202) 512-2834 or 
[email protected]. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

USPS and the Mailing Industry Have Undertaken Numerous Mail-Related 
Recycling Initiatives: 

Stakeholders Cited Five USPS Mail-Related Recycling Opportunities, but 
USPS Would Need to Assess Several Factors in Deciding Whether to Adopt 
Them: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Other USPS Actions to Increase the Amount of Mail with 
Environmentally Preferable Attributes: 

Appendix III: Depiction of Various Mail-Related Recycling Logos: 

Appendix IV: Other Stakeholder Initiatives to Increase the Amount of 
Mail with Environmentally Preferable Attributes: 

Appendix V: DMA's List of 15 Environmentally Preferable Business 
Practices: 

Appendix VI: Comments from USPS: 

Appendix VII: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Relevant Goals of the Five Greening the Mail Task Force 
Subcommittees: 

Table 2: Stakeholders Interviewed: 

Figures: 

Figure 1: Mail-Related Recycling Logos: 

Figure 2: Logos Indicating Paper Products Contain Recycled Materials or 
Are Recyclable: 

Abbreviations: 

DMA: Direct Marketing Association: 

UAA: undeliverable-as-addressed: 

USPS: United States Postal Service: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

June 3, 2008: 

Congressional Committees: 

During fiscal year 2007, United States Postal Service (USPS) customers 
sent approximately 104 billion pieces of mail (mailpieces) as Standard 
Mail, the primary class of mail used for advertising. Over time, most 
of these mailpieces were presumably discarded as waste. Depending on 
how the discarded mailpieces are disposed of, they could be recycled, 
placed into landfills, or incinerated. The U.S. Environmental 
Protection Agency reports that during 2006, Standard Mail comprised 
about 2.3 percent (5.9 million tons) of all municipal solid waste. Of 
this amount, recycling efforts captured about 39 percent, while 
landfills or incinerators received the remaining quantity. USPS 
discarded about 6.1 billion undeliverable-as-addressed (UAA) Standard 
Mail mailpieces (about 317,000 tons) in 2006, while mailers discarded 
the remainder.[Footnote 1] With the exception of UAA Standard Mail, the 
responsibility for recycling discarded mail primarily lies with mail 
recipients. 

USPS, which receives only a small portion of its funding from federal 
appropriations, is expected to generate sufficient annual revenue to 
cover its costs. In fiscal year 2007, however, USPS' operating costs 
exceeded its revenues by over $5 billion, largely due to the agency's 
advance payments for retiree health benefits. Furthermore, USPS expects 
to incur substantial additional costs that will need to be offset by 
revenue increases and improved operating efficiencies. USPS has 
reported that mixed paper (i.e., UAA mailpieces, including newsprint, 
and mail discarded by recipients in postal facility lobbies) account 
for up to 70 percent of its waste stream. Recycling these materials 
provides USPS with a means to generate substantial revenues, 
significantly reduce its waste disposal costs, and improve its 
financial position. In addition, because recycling discarded mail- 
related materials results in a variety of environmental benefits, 
including reductions in the amount of mail incinerated or placed in 
landfills,[Footnote 2] recycling these materials provides USPS with a 
means to enhance its long-standing commitment to environmental 
leadership. 

During fiscal year 2007, revenue generated from Standard Mail comprised 
about 28 percent ($20.8 billion) of USPS' total revenue, and Standard 
Mail constituted the largest class of mail by volume (about 49 percent 
of 212 billion mailpieces). The prevalence of Standard Mail is expected 
to increase, in part, because businesses, non-profit organizations, and 
others view it as an effective way to (1) provide consumers with 
information about their products and services and (2) solicit 
contributions from mail recipients. Some critics, however, view 
Standard Mail as an annoyance that also poses identify theft concerns 
and negatively impacts the environment. In response, numerous state 
legislatures introduced "Do Not Mail" bills that, if enacted, would 
require mailers to remove registered individuals from their mailing 
lists (similar to the national "Do Not Call" registry).[Footnote 3] 

In response to the 2006 Postal Accountability and Enhancement Act and 
agreements reached with relevant congressional offices, this report 
addresses (1) recent mail-related recycling accomplishments 
(initiatives)[Footnote 4] undertaken by USPS, the mailing industry, and 
others and (2) additional recycling opportunities that USPS could 
choose to engage in, or influence mailers to undertake. Pursuant to our 
legislative mandate, we issued a report on our interim results on 
December 20, 2007.[Footnote 5] This report updates our interim report 
and describes in more detail the key recycling initiatives that 
recently have been undertaken by USPS, the mailing industry, and other 
stakeholders. These initiatives include efforts to recycle mail-related 
materials,[Footnote 6] including UAA Standard Mail, and to increase the 
amount of mail with environmentally preferable attributes. Mail with 
environmentally preferable attributes includes mail that (1) contains 
paper with recycled paper fiber (recycled paper); (2) uses paper from 
responsibly-managed forests (certified paper);[Footnote 7] (3) is 
designed to use materials efficiently, (such as "two-way" envelopes); 
(4) is accurately addressed for delivery; and (5) is targeted to mail 
recipients who may wish to receive it. This report also describes 
additional stakeholder-identified opportunities for USPS to engage in 
(or influence mailers to undertake) mail-related recycling initiatives, 
and identifies factors such as cost; feasibility, including logistical 
considerations; and mission compatibility that USPS would need to 
assess prior to adopting the opportunities. 

To accomplish our objectives we, among other activities, (1) 
interviewed a wide range of USPS officials and stakeholders from about 
40 other organizations, including representatives from mailing, paper 
recycling, and environmental advocacy organizations; (2) toured various 
facilities, including USPS facilities in Baltimore and Philadelphia, a 
paper recycling facility, and a printing facility; (3) attended 
meetings of the "Greening the Mail Task Force"--a committee of USPS, 
mailing industry, and other stakeholders that addresses environmental 
issues regarding the mail; and (4) reviewed and analyzed relevant 
documentation. We discussed matters related to recycling several 
classes of mail with stakeholders; however, we primarily focused on 
Standard Mail because of (1) its increasing prominence in the mail 
stream; (2) its contribution to the municipal solid waste stream; (3) 
USPS' responsibility for discarding large volumes of UAA Standard Mail; 
and (4) the issues critics cite related to Standard Mail, which are 
reflected in numerous "Do Not Mail" state legislative initiatives. 
While there are a variety of ways to consider the environmental impacts 
of mail, this report focuses on the role recycling plays in eliminating 
mail and mail-related materials from municipal solid waste, increasing 
USPS' revenue, decreasing USPS' waste disposal costs, and enhancing 
USPS' commitment to environmental leadership. Appendix I provides a 
more detailed explanation of our scope and methodology. 

We conducted this performance audit from April 2007 to June 2008 in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Results in Brief: 

USPS and the mailing industry have undertaken numerous initiatives to 
increase (1) the volume of mail-related materials recycled and (2) the 
amount of mail with environmentally preferable attributes. USPS has 
five key recycling-related initiatives underway. For example, USPS 
recently established annual goals to increase its revenue from mail- 
related recycling from $7.5 million in fiscal year 2007 to $40 million 
in fiscal year 2010. These goals do not reflect the full financial 
benefit attributable to mail-related recycling, however, because they 
exclude the savings that result from lower waste disposal costs that 
accompany increased recycling. At the conclusion of our review, USPS 
had not agreed to revise its goals or to adopt additional goals that 
reflect its full financial benefit. Furthermore, while USPS intends to 
develop a plan to help it achieve its recycling revenue goals, it is 
not clear whether this plan will (1) specify how progress toward the 
goals will be measured or (2) ensure that the data USPS will use to 
measure its progress are accurate, reliable, and collected using a 
consistent method. Similarly, although USPS also has launched a pilot 
recycling program in New York City, it is not clear whether, or to what 
extent, USPS will require its managers at other facilities to adopt, as 
applicable, feasible, mission compatible, and appropriate in view of 
cost and other considerations, the lessons learned from the pilot. USPS 
also developed, among other initiatives, a task force to increase the 
amount of mail with environmentally preferable attributes. 
Representatives of the mailing industry and other stakeholders also 
have undertaken a wide range of initiatives to, among other actions, 
increase the amount of mail that is recycled. For example, three 
mailing industry associations recently introduced separate recycling 
awareness campaigns to encourage mail recipients to recycle their 
catalogs, envelopes, and magazines. Other stakeholders, such as the 
National Recycling Coalition; Time, Inc.; and Verso Paper, have 
initiated a campaign to increase the volume of catalogs and magazine 
recycled in selected cities. In addition, the Direct Marketing 
Association--whose members collectively send about 80 percent of all 
Standard Mail--is undertaking several initiatives, including an effort 
to encourage mailers to use environmentally preferable mail attributes. 

USPS, mailing industry, and other stakeholders we interviewed 
identified five opportunities that USPS could choose to undertake to 
increase the volume of mail-related materials it recycles and to 
encourage mailers to increase the amount of mail with environmentally 
preferable attributes. The five opportunities stakeholders cited most 
frequently were for USPS to: 

* Implement a program for recognizing mail-related recycling 
achievements. 

* Increase awareness among mail recipients that mail is recyclable and 
encourage them to recycle their mail through, among other actions, 
collaboration with mailing industry and other stakeholder initiatives. 

* Collaborate with parties interested in increasing the supply of paper 
fiber available for recycling. 

* Establish a special, discounted postal rate--or "Green Rate"--as a 
means of inducing mailers to adopt one or more environmentally 
preferable attributes in their mailpieces. 

* Initiate a "mail take-back" program in locations that do not have 
access to municipal paper recycling. 

Each of these opportunities appears to be consistent with (1) the 
agency's long-standing commitment to environmental leadership and (2) 
the Postmaster General's recent commitments to both minimize the 
agency's impact on every aspect of the environment and to act as a 
positive environmental influence in U.S. communities. USPS would 
nonetheless need to balance those commitments, as well as the potential 
environmental benefits that those opportunities might provide, against 
factors such as costs to USPS, feasibility (including logistical 
considerations), and compatibility with USPS' mission when deciding 
whether to adopt these opportunities. For example, while the costs 
associated with implementing a program for recognizing mail-related 
recycling achievements are likely to be minimal (and more than offset 
by increases in USPS' revenues), the remaining four opportunities 
necessitate additional cost consideration. For example, two of the 
opportunities--increasing awareness about mail recycling and initiating 
a Green Rate--appear to have little likelihood of increasing the 
agency's revenue. Furthermore, the remaining two opportunities-- 
collaborating with parties interested in increasing the supply of paper 
fiber available for recycling and initiating a mail take-back program-
-may not generate sufficient revenues to cover their costs. Depending 
on the magnitude of variance between the expected costs and revenues, 
USPS may find implementing one or more of the opportunities 
unacceptable. As we recently testified, USPS faces multiple short-and 
long-term pressures in improving its operational efficiency, increasing 
its revenues, and controlling its costs--some of which are increasing 
faster than the overall inflation rate.[Footnote 8] In addition, unlike 
in the past, USPS is now subject to an inflation-based cap on the 
prices it can charge for its goods and services.[Footnote 9] 

To increase USPS' recycling of mail-related materials and increase the 
amount of mail with environmentally preferable attributes, we 
recommend, among other actions, that the Postmaster General direct the 
Manager of Environmental Policy and Programs and other parties, as 
appropriate, to (1) require its managers at other facilities to adopt 
applicable lessons learned from its New York City recycling pilot and 
(2) assess the environmental benefits of the mail-related recycling 
opportunities identified in this report, and any others, and adopt 
those opportunities that are feasible, compatible with USPS' mission, 
and appropriate in view of cost and other considerations. 

USPS provided its written comments on a draft of this report by letter 
dated May 2, 2008. These comments are summarized below and are 
included, in their entirety, as appendix VI to this report. USPS agreed 
with three of our four recommendations and stated that it had begun 
initiating actions to implement them. USPS also agreed, in principle, 
with our remaining recommendation to adopt applicable lessons learned 
from its New York City recycling pilot nationwide, where feasible, 
mission compatible, and appropriate in view of cost and other 
considerations. USPS stated, however, that it cannot require all of its 
facility managers to adopt these lessons since "not all lessons learned 
are applicable nationwide." We recognize that the pilot's lessons will 
not be applicable at every postal facility and, thus, clarified the 
recommendation to avoid confusion. 

Background: 

As the primary mail carrier in the United States, USPS' mission is to 
provide the nation with affordable and universal mail service. USPS' 
authority was revised on December 20, 2006, with the enactment of the 
Postal Accountability and Enhancement Act.[Footnote 10] Through this 
act, Congress provided USPS with tools and mechanisms to help ensure 
that USPS is efficient, flexible, and financially sound. The act also 
introduced a rate cap for many postal services. While Congress oversees 
USPS and provides direction to the agency on its operations and other 
matters, USPS receives only a small portion of its funding from federal 
appropriations.[Footnote 11] 

According to a 2001 Mailing Industry Task Force study,[Footnote 12] the 
mailing industry includes businesses, organizations, and other parties 
(mailers) that send and rely on mail to maintain contact with their 
customers. The mailing industry also encompasses mail preparers, 
including printers and businesses that send or receive mail on behalf 
of a third party. Vendors and suppliers of the hardware, software, and 
labor related to mail processing, such as companies who help mailers 
improve the accuracy of their mailing lists, also are included in the 
mailing industry, according to this study. 

USPS offers several classes of mail, including First-Class, Standard, 
and Periodical Mail. The price for each class of mail varies, as does 
the level of service that USPS provides. Mailers, including both 
household and business customers, use First-Class Mail when sending 
personal mail and personalized business correspondence, such as 
letters, greeting cards, bills, and account statements. Mailers also 
may use First-Class Mail to send advertisements and merchandise. 
Standard Mail is the primary mail class for advertisements sent in bulk 
quantities and cannot be used for sending personal correspondence, such 
as handwritten letters, bills, or account statements. Periodical Mail 
primarily is comprised of newspapers and magazines. Standard Mail rates 
are generally lower than First-Class Mail rates, in part, because USPS 
typically does not provide services such as return-to-sender and 
forwarding for UAA Standard Mail.[Footnote 13] 

USPS and the mailing industry view Standard Mail as an important 
advertising medium for businesses, non-profit organizations, and other 
parties who seek to inform mail recipients about their products and 
services or to solicit contributions. While USPS currently receives 
about half of its revenue from First-Class Mail, Standard Mail became 
the largest class of mail (by volume) in fiscal year 2005. During 2005, 
mailers spent about $56.6 billion on direct mail advertising-- 
comprising about 21 percent of all U.S. expenditures for 
advertising.[Footnote 14] USPS expects the volume of Standard Mail to 
continue to grow. 

UAA mail is mail that USPS cannot deliver to a specified address due to 
an incomplete, illegible, or incorrect address or insufficient postage, 
among other reasons. USPS' treatment of UAA mail depends on the mail 
class. USPS forwards UAA First-Class Mail to the addressee, returns it 
to the sender, or, if the return address is missing, sends it to a USPS 
Mail Recovery Center.[Footnote 15] In general, USPS retains UAA 
Standard Mail and treats it as waste. Because of the large volume of 
UAA Standard Mail that USPS discards annually (about 317,000 tons in 
2006), USPS focuses most of its mail-related recycling efforts on this 
material. USPS also treats the mail discarded by recipients in postal 
facility lobbies (discarded lobby mail) as waste. While USPS does not 
know how much mail post office box holders and other recipients discard 
in its lobbies, a USPS official stated that the amount is "trivial" 
relative to its total volume of mail-related waste. 

USPS has reported that mixed paper (i.e., UAA mailpieces, including 
newsprint, and discarded lobby mail) accounts for up to 70 percent of 
its waste stream. According to USPS, these materials can be used to 
make everything from low-grade paper products, such as hand towels and 
tablet backings, to wallboard and stock for fuel pellets that can be 
burned with coal to reduce harmful air emissions. Furthermore, 
according to the agency, the large volume of its UAA mail is an 
attractive and reliable source of clean mixed paper needed for 
manufacturing these and other products. 

A USPS-sponsored study reported that in fiscal year 2004, UAA mail cost 
the agency more than $1.8 billion,[Footnote 16] which represented about 
2.6 percent of USPS' total expenses (approximately $69 billion). About 
two-thirds of UAA mail costs resulted from forwarding mail to the 
intended recipients ($422 million--23 percent) or returning it to the 
sender ($822 million--44 percent). The remaining one-third of UAA mail 
costs are the result of processing waste ($270 million--15 percent), 
correcting addresses ($197 million--10 percent), processing address 
change requests ($132 million--7 percent), and general administration 
and support ($24 million--1 percent). Furthermore, according to USPS, 
creating and sending mail that cannot be delivered costs businesses 
more than $2 billion annually. 

With the exception of UAA Standard Mail, the responsibility for 
recycling discarded mail primarily lies with mail recipients. While the 
majority of mail is recyclable,[Footnote 17] according to the 
Environmental Protection Agency, mail recipients and others recycled 
only about 39 percent of the Standard Mail they received and 
subsequently discarded in 2006. Studies find that the volume of 
products recycled depend on, among other matters, whether a recipient 
knows that a product is recyclable and whether the recipient has access 
to a recycling program or facility. According to one study, over 40 
percent of the public are unaware that it can recycle mail.[Footnote 
18] Numerous stakeholders we interviewed confirmed this lack of 
recycling awareness. Even if individuals are aware that mail is 
recyclable, according to a 2005 survey conducted by the American Forest 
and Paper Association, residents in about 31 percent of U.S. 
communities (14 percent of the population) do not have access to paper 
recycling programs.[Footnote 19] In addition, while a 2006 survey by 
the Federal Trade Commission found that only a small number of victims 
(2 percent) reported that the theft of their identify was connected to 
the mail, several stakeholders told us that identity theft concerns 
prevent some recipients from recycling their mail. In December 2006, we 
reported on efforts to increase the volume of materials recycled and 
found that, to increase recycling, U.S. municipalities need to conduct 
public education campaigns and ensure that access to recycling is both 
convenient and easy.[Footnote 20] Further, we identified federal policy 
options that would help municipalities increase the volume of materials 
recycled, including the establishment of (1) a nationwide education 
campaign to inform the public about recycling and (2) programs that 
enable consumers to recycle products by returning them to the 
manufacturer or some other party for recycling. These programs are 
known as "take-back" programs. 

USPS and the mailing industry formed a Greening the Mail Task Force in 
1996 to identify cost-effective ways to integrate environmental 
considerations into mailing practices and business processes. The task 
force issued a final report of its activities in 1999, including its 
efforts to identify "green" mail attributes (environmentally preferable 
attributes). According to the task force, environmentally preferable 
mail includes, among other attributes: 

* Mail that contains recycled paper. 

* Mail that uses certified paper. 

* Mail that is designed to use materials efficiently (such as "two-way" 
envelopes). 

* Mail that is accurately addressed for delivery.[Footnote 21] 

* Mail that is targeted to recipients who may wish to receive it. 
[Footnote 22] 

USPS' Environmental Policy and Programs organization is principally 
responsible for increasing the agency's recycling of mail-related 
materials and is the focal point for executing its environmental policy 
throughout the agency. USPS also has organizations that, among their 
other responsibilities, attempt to increase the amount of mail with 
environmentally preferable attributes. For example, Address 
Management's goal is to decrease the amount of UAA mail. To accomplish 
this, the organization provides mailers with tools to better manage the 
quality of their mailing lists while, according to USPS, striving to 
maximize its ability to efficiently deliver mail as addressed. The 
Product Development organization within Marketing helps manufacturers 
develop mail-related products that contain recycled materials. Finally, 
USPS' Sales organization--also within Marketing--promotes the use of 
environmental preferable attributes in direct mail advertising and in 
USPS shipping materials. 

USPS and the Mailing Industry Have Undertaken Numerous Mail-Related 
Recycling Initiatives: 

USPS and the mailing industry have undertaken numerous initiatives to 
increase the recycling of mail-related materials and increase the 
amount of mail with environmentally preferable attributes. For example, 
USPS has undertaken five key mail-related recycling initiatives, 
including the establishment of annual goals to increase its recycling 
revenue from $7.5 million in fiscal year 2007 to $40 million in fiscal 
year 2010 and a pilot recycling program in New York City. 
Representatives of the mailing industry and other stakeholders also 
have undertaken a wide range of initiatives to, among other actions, 
increase the amount of mail that is recycled. For example, three 
mailing industry associations recently introduced separate recycling 
awareness campaigns to encourage mail recipients to recycle their 
catalogs, envelopes, and magazines. In addition, the Direct Marketing 
Association--whose members collectively send about 80 percent of all 
Standard Mail--is undertaking several initiatives, including an effort 
to encourage mailers to use environmentally preferable mail attributes. 

USPS Has Undertaken Five Key Initiatives to Increase Its Recycling of 
Mail-Related Materials: 

USPS has undertaken five key initiatives to increase its recycling of 
mail-related materials. Specifically, USPS recently (1) established 
goals for increasing its recycling revenue; (2) refocused its attention 
on environmental matters, including mail-related recycling, and intends 
to require recycling where cost-effective and feasible; (3) 
consolidated waste management contracts to generate increased recycling 
revenues and reduce its waste disposal costs; (4) launched a pilot 
recycling program in New York City; and (5) implemented tools to track 
the environmental performance of its areas and districts. While USPS 
recently established goals for increasing its recycling revenues, 
inconsistencies in the way USPS collects data, if not resolved, will 
hamper efforts to measure its progress in meeting these goals. 
Furthermore, at the conclusion of our review, it was not clear whether, 
or to what extent, USPS would require its managers at other facilities 
to adopt--where applicable, feasible, mission compatible, and 
appropriate in view of cost and other considerations--lessons learned 
from its New York City pilot. 

USPS Established Goals for Increasing Its Recycling Revenue, but 
Inconsistencies in the Way It Collects Data, If Unresolved, Will Hamper 
Efforts to Measure Its Progress: 

In March 2008, USPS established annual goals for increasing the $7.5 
million it generated from recycling mail-related materials in fiscal 
year 2007. Specifically, USPS intends to generate $15 million in mail- 
related recycling revenue in fiscal year 2008, $30 million in fiscal 
year 2009, and $40 million in fiscal year 2010. According to USPS, 
reaching its fiscal year 2010 goal could also reduce its solid waste 
disposal costs by $10 million annually. Thus, in fiscal year 2010, USPS 
could realize a full financial benefit of $50 million. To help reach 
its initial fiscal year 2008 goal, according to USPS officials, each of 
the agency's nine geographic areas developed a plan to generate $2 
million from recycling in fiscal year 2008.[Footnote 23] Longer term, 
according to these officials, the $40 million goal for fiscal year 2010 
is based on the expectation that each of its 82 districts will generate 
an average of about $500,000 in recycling revenues. 

Such goals are a step in the right direction and address the need for 
USPS to generate additional revenue, which is one of the agency's four 
strategic goals. However, by excluding savings that result from lower 
waste disposal costs, the goals do not reflect the full financial 
benefit attributable to mail-related recycling. This is because when 
USPS facility managers implement mail-related recycling programs, their 
facilities generate less waste, thereby reducing the facilities' waste 
disposal costs (in addition to generating recycling revenue). Revising 
the agency's goals to include the savings from lower waste disposal 
costs or adopting additional goals to reflect the full financial 
benefit of recycling would help focus USPS employees on the need to 
achieve greater cost reductions--consistent with a second USPS 
strategic goal.[Footnote 24] According to USPS officials, USPS is 
developing the capacity to track solid waste disposal volumes and 
intends to develop a plan for achieving its recycling goals. However, 
at the conclusion of our review, it had not agreed to revise its goals 
or to adopt additional goals for measuring its savings from lower waste 
disposal costs to reflect the full financial benefit attributable to 
mail-related recycling. 

Regardless of whether USPS finds it beneficial to revise its goals to 
reflect the full financial benefit attributable to mail-related 
recycling, in order to measure its progress, USPS will need to (1) 
specify how it will measure its progress toward its goals and (2) 
ensure that its organizations collect and report accurate, reliable, 
and consistent data, which, according to agency officials, does not 
presently occur. For example, according to both USPS officials and our 
analysis of USPS documentation some district facilities combine 
recycling revenues with waste disposal costs. Additionally, our 
analysis of USPS documentation indicates that in fiscal year 2006 at 
least one large district facility combined recycling revenues with 
waste savings attributable to recycling--which, together, comprise the 
full financial benefit of recycling.[Footnote 25] Inconsistent 
reporting practices hamper efforts to accurately measure the agency's 
progress in meeting its recycling revenue goals. To partially address 
this problem, in March 2008, the agency's accounting organization sent 
an e-mail to USPS area managers requesting that they report recycling 
revenues separately from waste disposal costs. While this request 
addresses the need to report recycling revenue separately, it does not 
constitute a requirement for the managers at the area-, district-, or 
facility-level to do so. Furthermore, the e-mail does not address 
matters related to the reporting of USPS' savings from lower waste 
disposal costs, or require these managers to report data on their 
savings using a consistent method. Finally, at the conclusion of our 
review, USPS had neither (1) specified how it will measure progress 
toward its goals nor (2) required its organizations to collect and 
report accurate, reliable, and consistent data. Without taking further 
action, USPS may not be able to accurately assess its progress toward 
meeting its goals--regardless of which goals it eventually adopts. 

USPS Recently Refocused Its Attention on Environmental Matters, 
including Mail-Related Recycling, and Intends to Require Recycling 
Where Cost-Effective and Feasible: 

While USPS has had a mail-related recycling program in place since the 
1990s, security concerns arising from the introduction of anthrax in 
the mail stream in 2001 caused USPS to deemphasize recycling until 
recently, according to USPS officials. In December 2007, however, USPS 
announced its intention to refocus its attention on environmental 
matters, including the recycling of UAA mail and mail-related 
materials.[Footnote 26] According to USPS, recycling will help protect 
the value of Standard Mail as a form of advertising, generate 
additional revenues, and reduce USPS' waste disposal costs. Recycling 
UAA mail and other mail-related materials also provides USPS with a 
means to enhance its long-standing commitment to environmental 
leadership. Furthermore, recycling these materials appears to be 
consistent with the Postmaster General's recent commitments to minimize 
the agency's impact on every aspect of the environment and to act as a 
positive environmental influence in U.S. communities. 

As part of its refocused attention on environmental matters, in July 
2007, USPS issued a revised policy--termed a Management Instruction-- 
that addresses its waste management issues.[Footnote 27] With respect 
to recycling, the policy encourages district managers and installation 
heads to establish recycling programs to collect UAA mail and discarded 
lobby mail in central locations. While the policy indicates that 
employees at USPS' plants and post offices "should recycle" these mail- 
related materials, they are not required to do so if it is not cost- 
effective or logistically feasible. For example, according to USPS 
officials, recycling may not be cost-effective or logistically feasible 
at facilities that lack storage space or generate a limited quantity of 
recyclable mail-related materials.[Footnote 28] 

The July 2007 policy superseded USPS' previous policy and guidelines, 
issued in September 1995,[Footnote 29] which (1) were specific to 
recycling mail-related materials and (2) provided significantly more 
guidance on recycling UAA mail, discarded lobby mail, and facility 
paper waste. In addition, while not explicitly stated, the 1995 policy 
"technically required" facility managers to implement mail-related 
recycling programs at all USPS facilities that generate these types of 
waste, according to agency officials. 

According to the prior policy, effective targeting of UAA mail can 
achieve many objectives. For example, it "can help meet postal waste 
reductions goals and implement more efficient and environmentally sound 
alternatives to solid waste disposal practices." In addition, the 1995 
policy noted that such an "effort saves [USPS] money in solid waste 
disposal and reduces criticism that third-class [Standard Mail] mail 
volumes contribute to municipal solid waste problems." Finally, 
according to the prior 1995 policy, recycling UAA mail also enhances 
the viability of Standard Mail as an environmentally friendly 
advertising medium. To help USPS accomplish these objectives, the 1995 
policy required facility managers to (1) keep records of revenues 
generated by recycling, as well as the costs and quantities of solid 
waste generated at their facilities; (2) conduct an annual evaluation 
of their practices related to discarded mixed paper, disposal methods, 
and recycling alternatives; and (3) supply information on their annual 
evaluations, including the costs, volumes, disposal methods, recycling 
alternatives, and barriers associated with implementing a mail-related 
recycling program at their facilities to his or her district manager. 
The prior policy also established others responsibilities. For example, 
area managers were responsible for ensuring that facilities that 
generate UAA mail conducted the annual evaluations and for assisting 
district managers in finding markets for the material. USPS' latest 
policy, issued in 2007, does not address these and other matters. 

During the course of our work, we discussed differences between the two 
policies with USPS officials, including the requirement for an annual 
evaluation of facility practices related to discarded mixed paper. 
According to USPS officials, the omission of this requirement was 
unintended. To address this omission as well as others, the officials 
indicated that USPS would develop a new policy that will, among other 
things, (1) provide employees with specific information on how to 
implement recycling programs at their facilities, (2) require USPS 
facility managers to implement mail-related recycling initiatives 
unless doing so is not cost-effective or logistically feasible, and (3) 
specify requirements for reporting data on USPS' mail-related recycling 
activities. USPS expects to release its revised policy, as well as 
guidance for implementing its recycling program, later this year. 

USPS Consolidated Contracts to Increase Its Recycling Revenue and 
Reduce Its Waste Disposal Costs: 

To increase its recycling revenues and reduce its waste disposal costs, 
USPS began a multi-phased process to consolidate its waste disposal and 
recycling contracts at USPS facilities nationwide. In the first phase, 
completed in January 2006, USPS centralized its negotiation and 
management of all waste disposal and recycling contracts at the 
Memphis, Tennessee, Category Management Center (Memphis Center). 
[Footnote 30] In the second phase, which recently began, the Memphis 
employees are working with managers at facilities with existing waste 
disposal and recycling contracts and are attempting to convince these 
managers to incorporate their facilities within larger, regionally-
based USPS waste disposal and recycling contracts.[Footnote 31] Such 
contract consolidations are consistent with our prior findings. 
Specifically, in 2004, we reported that consolidating contracts allows 
private-sector companies to leverage their buying power and identify 
more efficient ways to procure goods and services.[Footnote 32] 

The Memphis Center offers facility managers four types of contracts: 
(1) waste disposal only; (2) removal of recyclables only; (3) removal 
of waste and recyclables; and (4) Total Solid Waste Management 
contracts, which cover both waste disposal and recycling.[Footnote 33] 
In fiscal year 2007, the four types of contracts managed by the Memphis 
Center resulted in approximately $6.6 million in recycling revenues 
(about $6 million) and waste disposal cost savings (about $600,000). 

Total Solid Waste Management contracts attempt to both (1) maximize 
recycling revenues and (2) minimize waste disposal costs by using two 
methods to collect and transport mail-related recycling materials. The 
first method--"backhauling"--uses USPS' labor and existing 
transportation network to collect and transport mail-related recyclable 
materials from local USPS facilities (e.g., post offices) to a single 
USPS location, such as a mail processing and distribution center, where 
the materials are consolidated prior to USPS' subsequent delivery to a 
paper mill or other vendor interested in purchasing the materials. 
[Footnote 34] When consolidation at a single USPS facility is not 
feasible, USPS uses a second method--"milk runs"--to collect its 
recyclable materials. Milk runs use contractors, such as paper brokers 
and other vendors, to collect recyclable materials stored at local USPS 
facilities and transport them to their destination. USPS officials 
stated that because the contractor uses its resources, including its 
labor and transportation, to collect and transport the materials, USPS 
must pay for these services--a factor that reduces both USPS' recycling 
revenues and its savings from lower disposal costs. 

Total Solid Waste Management contracts may include a shared savings 
component with the contractor, whereby the contractor receives a 
portion of USPS' recycling revenues and savings from lower waste 
disposal costs. Cost-sharing arrangements are intended to encourage the 
contractor to implement initiatives that maximize USPS' recycling 
revenues while minimizing its waste disposal costs. One example of such 
a contract is USPS' contract with Rand-Whitney, which covers 457 
facilities throughout Pennsylvania. Rand-Whitney developed a recycling 
program for each facility that, according to documentation supplied by 
USPS, generated $177,000 in recycling revenues and reduced USPS' waste 
disposal costs by $98,000--for a total financial benefit of $275,000 
from July 2006 to June 2007. Because this contract allows Rand-Whitney 
to share USPS' revenues and savings, Rand-Whitney received 25 percent 
of this total, or approximately $69,000, during the 12-month period. 

USPS Launched a Pilot Recycling Program in New York City: 

In an attempt to demonstrate the value of mail-related recycling 
programs, USPS began a pilot program in New York City in May 2007. The 
goal of the pilot--termed "New York City SOARs!" (Saving of America's 
Resources)--is to identify opportunities to establish and expand 
recycling programs in USPS facilities throughout New York City and, 
based on lessons learned, identify recycling practices that can be used 
in other USPS facilities.[Footnote 35] USPS is implementing the pilot 
in stages. The first stage assessed postal recycling activities 
underway in each of New York City's five boroughs,[Footnote 36] using a 
variety of factors, such as costs to USPS, feasibility (including 
logistical considerations), and mission compatibility. The report on 
the assessment, issued in September 2007, concluded that recycling in 
New York City (1) can generate recycling revenues, (2) will 
substantially reduce USPS' waste disposal costs, (3) will not interfere 
with postal operations, and (4) will require only a "modest 
incremental" effort to accomplish. 

Based on the results of the first stage, the report suggested specific 
recycling activities in each borough, including: (1) the initiation of 
backhauling recycling programs for UAA Standard Mail and mail-related 
materials in Manhattan, Brooklyn, and the Bronx, and the expansion of 
the existing backhauling program in Queens; (2) the implementation of 
milk runs for UAA Standard Mail and mail-related materials in Staten 
Island; (3) the designation of sufficient loading dock space at USPS 
processing and distribution centers in Manhattan to accommodate 
trailers for storing and transporting mail-related recycling materials; 
and (4) the establishment of recycling programs for discarded lobby 
mail in all five boroughs. According to USPS, it is optimistic that, by 
carefully implementing and enhancing mail-related recycling programs 
throughout New York City, it could generate approximately $1.3 million 
per year in recycling revenues and save an additional $800,000 in waste 
disposal costs.[Footnote 37] 

The pilot's second stage began in January 2008 and, in February 2008, 
according to USPS officials, the agency issued a solicitation for a 
contract to provide waste disposal and recycling services to USPS 
facilities in four of New York City's five boroughs--Brooklyn, the 
Bronx, Manhattan, and Queens. USPS expects the contract will begin in 
October 2008. This pilot is in its early stages and, at the conclusion 
of our review, USPS did not have a plan or timeline for, among other 
actions, ending the pilot program or issuing a final report on the 
pilot. Furthermore, it was not clear whether, or to what extent, USPS 
would require its managers at other facilities to adopt--where 
applicable, feasible, mission compatible, and appropriate in view of 
cost and other considerations--lessons learned from the pilot. 

USPS Has Implemented Tools to Track the Environmental Performance of 
Its Areas and Districts: 

USPS also has implemented tools for tracking the environmental 
performance of its areas and districts. One such tool, called an 
"environmental scorecard," tracks and ranks the environmental 
performance of USPS' nine geographic areas.[Footnote 38] In fiscal year 
2007, USPS used the tool to collect information needed to rank each 
area's environmental performance in 12 general areas, such as pollution 
prevention, that includes recycling.[Footnote 39] To measure 
environmental performance at the district level, USPS also created a 
budgetary line-item for tracking each district's recycling revenues. 

USPS plans to share the results of both its environmental evaluation 
tool and its analyses of the districts' recycling revenues (from the 
budgetary line-item) with its postal managers. Because USPS officials 
believe that the agency's employees are highly competitive, according 
to USPS officials, relative differences between the areas and districts 
are expected to foster competition and increase recycling revenues 
throughout the postal network. While USPS currently does not use the 
results of the environmental evaluation tool or its analyses of the 
districts' recycling revenues for recognizing significant mail-related 
recycling achievements, according to USPS officials, USPS could choose 
to do so in the future. In the interim, according to these officials, 
USPS (1) is considering establishing a program to nominate facilities, 
teams, and individuals for environmental excellence in seven 
environmental categories--one of which includes recycling--and (2) has 
changed its accounting policy to allow districts to receive credit for 
the revenue each district generates from recycling. 

USPS Has Undertaken Two Multi-Faceted Initiatives to Increase the 
Amount of Mail with Environmentally Preferable Attributes: 

To increase the amount of mail with environmentally preferable 
attributes, USPS has undertaken two multi-faceted initiatives. 
Specifically, USPS (1) initiated a second Greening the Mail Task Force 
to, among other activities, promote the use of environmentally 
preferable attributes in mail and (2) established a UAA mail cost 
reduction goal. It also has numerous actions underway that may help the 
agency meet its UAA mail cost-reduction goal. Such actions include 
USPS' implementation of a new mail processing method that identifies 
and redirects incorrectly addressed mail to the intended addressee 
before delivery is attempted. USPS also has taken other actions to 
increase the amount of mail with environmentally preferable attributes. 
We discuss these actions in appendix II of this report. 

USPS Initiated a Second Task Force to Increase the Amount of 
Environmentally Preferable Attributes in Mail: 

In September 2007, USPS initiated a second Greening the Mail Task Force 
to, among other goals, increase the amount of mail with environmentally 
preferable attributes. As discussed earlier, USPS disbanded the first 
task force in 1999 after it issued a final report that, among other 
matters, identified environmentally preferable attributes associated 
with mail. The most recent task force--formed to address mail-related 
issues on a long-term basis--includes USPS officials, mailing industry 
representatives, and other stakeholders. The task force has five 
subcommittees, each with a different goal. Table 1 identifies each of 
the subcommittees' relevant goals. 

Table 1: Relevant Goals of the Five Greening the Mail Task Force 
Subcommittees: 

Subcommittee: Education and Awareness on Sustainability and Value of 
the Mail; 
Relevant goals[A]: 
* Promote awareness that mail is recyclable; 
* Encourage enhanced environmental mail designs; 
* Encourage better address accuracy; 
* Provide accurate information to policy makers, mailers, and the press 
on the benefits of mail. 

Subcommittee: Improving Mail Recyclability and Source Reduction; 
Relevant goals[A]: 
* Assess the recyclability of mail products; 
* Identify recycling barriers; 
* Evaluate the conditions that impact successful mail delivery; 
* Identify ways to reduce UAA mail; 
* Minimize the environmental impacts associated with mail. 

Subcommittee: Recycling Collection of the Mail; 
Relevant goals[A]: 
* Increase paper recycling by implementing and supporting mail 
recycling initiatives in postal facilities, office buildings, and 
private residences. 

Subcommittee: Life-Cycle Analysis of Mail; 
Relevant goals[A]: 
* Provide the mailing industry's perspective on the "life-cycle 
inventory"[B] of mail and, if possible, conduct a full "life-cycle 
analysis" of the mail.[C]. 

Subcommittee: Standards and Certification; 
Relevant goals[A]: 
* Facilitate the identification and creation of environmental 
sustainability standards; 
* Facilitate a certification process for the life cycle of mail. 

Source: GAO analysis of Greening the Mail Task Force documentation. 

[A] For the purposes of this table, we have excluded goals that are not 
relevant to the topics discussed in this report. 

[B] According to USPS, a life-cycle inventory of the mail attempts to 
identify emissions of significant pollutants throughout the entire 
"life-cycle" of the mail, including emissions resulting from harvesting 
trees for paper; making the paper; turning the paper into mail; 
processing, sorting, and distributing the mail to consumers; and the 
end of the life-cycle--when the mail is eventually discarded. 

[C] A life-cycle analysis is similar to a life-cycle inventory, but is 
more costly, complex, and comprehensive to perform. If the life-cycle 
inventory shows that mail significantly impacts the environment, 
according to USPS, a life-cycle analysis would be conducted. At the 
conclusion of our review, we were unable to ascertain how such an 
analysis would affect mail-related processes and practices. 

[End of table] 

USPS Established a UAA Mail Cost Reduction Goal, and Actions Are 
Underway That May Help USPS Meet This Goal: 

USPS established a UAA mail cost-reduction goal in 2006 and has 
developed numerous tools that mailers can use to improve the accuracy 
of their mailing lists and reduce the amount of UAA mail they 
send.[Footnote 40] More recently, USPS introduced two new requirements 
that are expected to help USPS meet its UAA mail cost-reduction goal. 
In addition, USPS has implemented a new mail processing method that 
identifies and redirects incorrectly addressed mail to the intended 
addressee before delivery is attempted. 

USPS Established a UAA Mail Cost-Reduction Goal: 

In addition to its recent establishment of goals for increasing the 
revenue USPS generates from recycling mail-related materials, in 2006, 
USPS set a goal of reducing UAA mail by 50 percent by fiscal year 2010. 
In the summer of 2007, USPS clarified this goal, specifying that it 
applied to the cost--not the volume--of UAA mail. USPS is developing 
measures to accurately assess its progress in meeting the UAA mail cost 
reduction goal. According to USPS, its interim measures are not 
sufficient for this purpose; however, USPS officials believe that data 
from its May 2009 deployment of Intelligent Mail, which we discuss 
later in this report, will provide data needed to accurately measure 
its progress in meeting this goal. 

USPS' Tools for Improving the Accuracy of Mailing Lists Reduce UAA 
Mail: 

USPS has developed numerous tools that mailers can use to increase the 
amount of mail that is accurately addressed for delivery. Mail that is 
accurately addressed decreases UAA mail volume, which, in turn, 
decreases USPS' operational and waste disposal costs. Since these 
address accuracy tools decrease USPS' operational costs, USPS provides 
lower postage rates (worksharing rates)[Footnote 41] to mailers who use 
them. A partial description of some of USPS' address accuracy tools 
follows: 

* "Address Element Correction" identifies mailpieces that are 
potentially UAA and corrects small errors in the addresses (e.g., the 
omission of a directional indicator such as "NW," or errors that refer 
to an avenue as a street). 

* "Delivery Point Validation" verifies that the address on a mailpiece 
exists in USPS' database of addresses to which it delivers. 

* "National Change-of-Address LINK" allows mailers to check their 
mailing lists against USPS' National Change-of-Address database, which 
contains updated address information for mail recipients who have filed 
change-of-address notices with USPS. 

* "Address Change Service" allows mailers to receive, for a fee, 
electronic notices that inform them when USPS cannot deliver their 
mailpieces. For First-Class Mail, these electronic notices reduce the 
amount of mail USPS must return to the sender, thereby decreasing UAA 
mail and USPS' operating costs. For Standard Mail--which USPS generally 
is not obligated to return to the sender--the electronic notices (1) 
inform mailers when their Standard mailpieces are UAA and (2) provide 
mailers with the correct addressing information. This information 
enables Standard mailers to update their mailing lists with corrected 
addresses prior to their next mailing, thereby reducing future UAA mail-
related costs. 

USPS Introduced Two New Requirements That Are Expected to Reduce UAA 
Mail: 

USPS also introduced two recent changes that, according to USPS 
officials, will reduce UAA mail and, consequently, help USPS meets its 
UAA mail cost reduction goal (i.e., a 50 percent reduction by fiscal 
year 2010). First, USPS has revised its "Move Update" requirement, 
which currently obligates First-Class mailers to use at least one 
approved address accuracy tool (such as National Change-of-Address LINK 
or the Address Change Service) to qualify for worksharing rates. In 
September 2007, USPS expanded this requirement to include mailers who 
send Standard Mail, effective November 23, 2008. Furthermore, USPS will 
begin requiring First-Class and Standard mailers to update their 
mailing lists--using an approved address accuracy tool--95 days prior 
to each of their mailings.[Footnote 42] 

Second, beginning in May 2009, USPS intends to require mailers to use a 
new barcode--called the "Intelligent Mail Barcode"--on their mailpieces 
to qualify for worksharing rates. According to USPS officials, the new 
barcode will allow USPS and mailers to track individual mailpieces as 
they move through the mail stream. USPS officials believe that the 
capability to track mailpieces will reduce UAA mail volumes--and, 
potentially, USPS operating costs--because mailers will be able to use 
the barcode to determine which of their mailpieces cannot be delivered 
and correct their mailing lists accordingly. USPS has initiatives 
underway, including an agreement with the Bank of America, to test the 
effectiveness of the Intelligent Mail Barcode before it is fully 
implemented.[Footnote 43] 

USPS Has Implemented a Method to Identify and Redirect Improperly 
Addressed Mail before Delivery Is Attempted: 

In September 2007, USPS also implemented a new, nationwide mail 
processing method--called the "Postal Automated Redirection System"-- 
that identifies and redirects mailpieces to individuals who have moved. 
According to USPS, if a mail recipient has moved and filed a change-of- 
address request with USPS, the automated redirection system identifies 
mailpieces addressed to his or her prior address when these mailpieces 
first enter the mail stream and initiates one of three possible 
actions. The first possible action is for USPS to immediately redirect 
the mailpiece to the new, correct destination. Second, if the mailpiece 
is not eligible for forwarding or if the mailer has authorized its 
disposal, USPS would remove the mailpiece from the mail stream and 
discard it. Finally, if requested by the mailer, USPS would return the 
mailpiece to the mailer (i.e., the sender). In the past, USPS 
redirected mailpieces only after delivery had been attempted. In such 
cases, Standard Mail was returned to the postal facility and discarded 
as waste (and disposed of through recycling or some other means), while 
First-Class Mail was processed and forwarded, returned to the sender, 
or sent to a mail recovery center. Because USPS generally does not 
forward or return UAA Standard Mail--regardless of when it is first 
detected--the automated redirection system will not reduce the amount 
of UAA Standard Mail that USPS must eventually discard. However, USPS 
officials believe the automated redirection system will reduce the cost 
of processing UAA mail, thereby contributing to the agency's UAA mail 
cost-reduction goal. 

The Mailing, Paper Recycling, and Environmental Advocacy Industries 
Have Undertaken Several Key Initiatives to Increase Mail-Related 
Recycling: 

In addition to USPS' efforts, the mailing industry and other 
stakeholders have undertaken several key initiatives to increase the 
volume of mail-related materials that are recycled. Some of these 
initiatives were developed by mailing industry associations, while 
others are the result of efforts by individual mailers and 
organizations in the paper and environmental advocacy industries. For 
example, in 2007, the Direct Marketing Association (DMA), the Envelope 
Manufacturers Association, and the Magazine Publishers of America 
developed nationwide mail recycling awareness campaigns.[Footnote 44] 
While similar in nature, the three programs use different logos to 
increase recycling awareness and are intended for different types of 
mailpieces (e.g., catalogs, envelopes, and magazines).[Footnote 45] DMA 
members who participate in the association's "Recycle Please" program 
are expected to include a logo in their catalogs and other mailpieces 
to encourage mail recipients to recycle their mailpieces after reading 
them. The envelope association's program--called "Please Recycle"-- 
promotes mail recycling by encouraging manufacturers to place a 
recycling logo on the front of envelopes and other packaging materials. 
Finally, the magazine association--which also calls its program "Please 
Recycle"--developed recycling logos and a full-page recycling 
advertisement that the association encourages its members to include in 
their magazines in order to increase the volume of magazines recycled. 
Participation in these recycling awareness campaigns varies. 
Specifically, based on our calculations of data provided by officials 
from DMA and the envelope and magazine associations, as of mid-March 
2008, about 2 percent, 30 percent, and 10 percent of their members 
participated in these programs, respectively.[Footnote 46] (The logos 
used for these recycling awareness campaigns are depicted in fig. 1 of 
app. III.) 

The second key recycling initiative involves the National Recycling 
Coalition,[Footnote 47] which intends to develop new recycling logos to 
replace the familiar "chasing arrows" logo currently displayed on many 
products. According to coalition representatives, one of the new logos 
will be specific to mail. The coalition believes that this logo--which 
has been used for many years--is confusing to the public. According to 
coalition officials, the logo has been repeatedly altered by product 
manufacturers and others since it was first introduced and, as a 
result, multiple versions of the logo currently exist, each of which 
signifies different meanings depending on its use.[Footnote 48] By 
updating the existing logo, the coalition hopes to, among other 
intentions, enhance consumer awareness that mail can be recycled. 
(Examples of selected "chasing arrows" recycling logos are depicted in 
fig. 2 of app. III.) 

Finally, in 2004, Time, Inc.; Verso Paper; and the National Recycling 
Coalition, among other parties, initiated the "Recycling Magazines is 
Excellent" project to inform consumers--primarily via advertisements in 
magazines--that catalogs and magazines are recyclable.[Footnote 49] 
These parties have piloted the project in five areas: Boston, 
Massachusetts; Prince George's County, Maryland;[Footnote 50] Portland, 
Oregon; Milwaukee, Wisconsin; and New York City, New York. According to 
a Time, Inc., official, in Boston, Portland, and Prince George's 
County, the program increased magazine recycling by 18 percent, 6 
percent, and 19 percent, respectively. Data for the Milwaukee and New 
York City pilots were not available at the conclusion of our review. 

The Mailing Industry and Other Stakeholders Have Undertaken Several Key 
Initiatives to Increase the Amount of Mail with Environmentally 
Preferable Attributes: 

In addition to their efforts to increase mail-related recycling, the 
mailing industry and other stakeholders have undertaken a variety of 
key initiatives to increase the amount of mail with environmentally 
preferable attributes. As described below, DMA is responsible for 
several of these initiatives. Other stakeholder initiatives, including 
those of individual mailers, environmental organizations, and other non-
profit organizations are discussed in appendix IV of this report. 

DMA Has Undertaken Several Key Initiatives to Increase the Amount of 
Mail with Environmentally Preferable Attributes: 

DMA has undertaken several key initiatives to increase the amount of 
mail with environmentally preferable attributes, particularly with 
respect to improving its members' mail targeting practices and the 
accuracy of their mailing lists. The first such effort, the Mail 
Preference Service,[Footnote 51] was introduced in 1971 and is a list 
of consumers who have requested not to receive (i.e., opt-out of) 
"prospecting mail" sent by DMA members.[Footnote 52] DMA requires its 
members to honor such requests and, consequently, forbids its members 
from selling or exchanging this list for any purpose other than 
removing prospective customers from their mailing lists.[Footnote 53] 
According to DMA officials, by eliminating prospecting mail, the 
Service (1) reduces the amount of mail a consumer receives by 
approximately 80 percent and (2) prevented 930 million pieces of 
unwanted mail from entering the mail stream in 2007.[Footnote 54] While 
DMA officials stated that the association works with consumer advocacy 
groups and other parties to inform consumers about the Mail Preference 
Service,[Footnote 55] a recent study conducted by Pitney Bowes 
indicates that two-thirds of Americans are not aware of the Service's 
existence. In part to address this lack of awareness, several parties 
within the environmental advocacy industry recently implemented other 
opt-out programs. As noted previously, these programs are discussed in 
appendix IV of this report. 

More recently, DMA formed the Committee on Environment and Social 
Responsibility, which is comprised of 16 executives from DMA's member 
organizations. Formed in 2005, the committee's goals are to identify 
challenges that direct marketers face with respect to "social 
responsibility" issues, such as environmental sustainability and 
corporate citizenship issues, and to develop guidance to address these 
challenges. The committee designed and executed a survey to benchmark 
the environmental practices of its members and developed a Web-based 
tool to help members evaluate their environmental practices in five 
areas: (1) paper procurement and use, (2) address quality (accuracy) 
and data management, (3) design, (4) packaging and printing, and (5) 
recycling and pollution reduction. The tool also enables mailers to 
create an environmental vision statement or policy statement for, among 
other purposes, displaying on their Web sites. DMA officials could not 
supply data on the extent to which its members use this tool. 

In 2007, DMA also passed the "Resolution Asserting Environmental 
Leadership in the Direct Marketing Community." The resolution calls on 
DMA members--by June 2008--to voluntarily establish internal 
measurements and benchmarks for assessing their business practices with 
respect to a list of 15 environmentally preferable practices. This 
list--called the "Green 15"--aligns with mailer business activities, 
such as paper procurement and use, mailing list accuracy, and mailpiece 
design. While the adoption of the 15 environmentally preferable 
practices is generally voluntary, in June 2008, DMA intends to 
establish goals and timetables for measuring its members' success in 
implementing these practices, which, according to DMA officials, could 
lead to future DMA requirements.[Footnote 56] DMA officials stated 
that, thus far, members generally have reacted positively to the list 
of 15 preferable practices, although some members have expressed 
concerns about purchasing recycled and certified paper. Specifically, 
members expressed concerns that (1) the supply of these products may 
not be sufficient to meet demand if DMA were to require its members to 
use them; and (2) due to the number of forest certification programs 
and the controversy over the programs' various merits, it is not clear 
which program they should use.[Footnote 57] (For more information on 
the Green 15, see app. V of this report.) 

Finally, in October 2007, DMA launched its "Commitment to Consumer 
Choice" program. Under this program, DMA members must, among other 
actions, include--on every direct mail solicitation they send--an 
option for consumers to opt-out of receiving future direct mail 
solicitations from that member, regardless of whether the member has 
previously established a business relationship with those customers. 
[Footnote 58] The new requirement, effective in October 2009, will 
strengthen DMA members' current obligation to provide mail recipients 
with one opt-out notice per year. The Commitment to Consumer Choice 
program also includes several other requirements related to consumer 
choice. Some of these requirements are new or modified, while others 
are long-standing.[Footnote 59] For example, DMA members must (1) 
disclose, upon consumer request, the source from which they obtained 
data about the consumer; (2) eliminate, upon consumer request, the 
transfer or rental of the consumer's personal information to other 
marketers; (3) increase the frequency with which they update their 
mailing lists against information in DMA's Mail Preference Service opt- 
out database (from a quarterly to a monthly basis); and (4) act on all 
customer opt-out requests within 30 days and for a period of at least 3 
years.[Footnote 60] 

According to DMA officials, DMA has an internal process for ensuring 
that members comply with its requirements.[Footnote 61] The process 
begins with DMA's Corporate Responsibility group, which receives all 
customer complaints regarding the receipt of unwanted mail.[Footnote 
62] If a pattern of complaints about a company emerges, DMA officials 
stated that the group would file a formal case before DMA's Committee 
on Ethical Business Practices.[Footnote 63] If the offending mailer 
still refuses to comply with DMA requirements, DMA's Board of Directors 
can, among other actions, expel the mailer from the association. 
According to DMA officials, however, member expulsions are rare. The 
officials explained that the association's goal is self-correction, not 
punishment, and that mailers normally alter their practices to avoid 
expulsion from DMA. 

Stakeholders Cited Five USPS Mail-Related Recycling Opportunities, but 
USPS Would Need to Assess Several Factors in Deciding Whether to Adopt 
Them: 

USPS, mailing industry, and other stakeholders we spoke to identified 
five opportunities that USPS could choose to undertake to increase its 
recycling of mail-related materials and to encourage mailers to 
increase the amount of mail with environmentally preferable attributes. 
[Footnote 64] The five opportunities cited most frequently were for 
USPS to (1) implement a program for recognizing mail-related recycling 
achievements; (2) increase awareness among mail recipients that mail is 
recyclable and encourage them to recycle their mail through, among 
other actions, collaboration with mailing industry and other 
stakeholder initiatives; (3) collaborate with parties interested in 
increasing the supply of paper fiber available for recycling; (4) 
establish a special, discounted postal rate--or Green Rate--as a means 
of inducing mailers to adopt one or more environmentally preferable 
attributes in their mailpieces; and (5) initiate a mail take-back 
program in locations that do not have access to municipal paper 
recycling. Each of these opportunities appears to be consistent with 
(1) the agency's long-standing commitment to environmental leadership 
and (2) the Postmaster General's recent commitments to both minimize 
the agency's impact on every aspect of the environment and to act as a 
positive environmental influence in U.S. communities. Based on our 
analysis, however, USPS would need to assess factors such as costs to 
USPS; feasibility, including logistical considerations; and mission 
compatibility in deciding whether to adopt the opportunities. 

Stakeholders Identified Five USPS Opportunities: 

The stakeholders we interviewed identified five opportunities that USPS 
could chose to undertake to increase its recycling of mail-related 
materials or to encourage mailers to increase the amount of mail with 
environmentally preferable attributes. First, several stakeholders 
stated that USPS could increase its mail-related recycling activities 
by offering recognition, financial awards, promotional opportunities, 
and other incentives to reward exemplary USPS recycling achievements. 
Three USPS officials stated that such incentives could target facility- 
level managers and employees, who are likely to be critical to the 
successful implementation of mail-related recycling programs. As 
discussed, USPS is considering establishing a program to nominate 
facilities, teams, and individuals for environmental excellence. As 
currently envisioned, the program would honor excellence in seven 
environmental categories, including "pollution prevention." While USPS 
is contemplating recognition for "improvements in recycling processes 
or programs" as part of its achievements related to pollution 
prevention, the program under consideration does not specifically 
recognize mail-related recycling achievements. An incentives program 
targeted specifically toward such achievements could foster greater 
competition throughout USPS, resulting in substantial increases in the 
agency's recycling revenue and significant savings in its waste 
disposal costs. Such a program could be based solely on recycling 
revenues, or include other metrics--such as the amount (tonnage) of 
materials recycled or its savings in waste disposal costs. 

Second, because mail recipients often are unaware that mail can be 
recycled, stakeholders suggested that USPS conduct a campaign to 
increase awareness among mail recipients that mail is recyclable and to 
encourage them to recycle their mail. Such a campaign could be 
collaborative in nature, unilateral, or undertaken through some 
combination of outreach efforts. For example, several stakeholders 
stated that USPS could collaborate with one or more of the ongoing 
mailing industry and other stakeholder initiatives to increase 
recycling awareness among mail recipients and to encourage them to 
recycle.[Footnote 65] Such an effort, among other matters, could (1) 
address common misconceptions related to the recyclability of various 
types of mail and (2) raise awareness about the primary causes of 
identity theft--two reasons why recipients may not recycle their mail. 
In addition, USPS could collaborate with members of the Greening the 
Mail Task Force to design and implement a plan to increase the public's 
awareness in these and other areas.[Footnote 66] If USPS desired to do 
so, stakeholders suggested that the agency also could take unilateral 
action to promote mail recycling by, for example, delivering an 
informational post card or some other form of communication to each 
address in America. Such an approach would be similar to USPS' actions 
to promote its various products and services nationwide, which, 
according to USPS officials, typically increase consumer awareness by 
nearly 30 percent. Stakeholders also suggested that USPS develop 
postmarks and stamps and install signage in postal lobbies to promote 
mail recycling. 

Third, numerous stakeholders suggested that USPS collaborate with 
parties, such as the American Forest and Paper Association and U.S. 
paper recycling companies, to increase the supply of fiber needed for 
manufacturing recycled paper products. According to these stakeholders, 
such fiber is typically in short supply domestically because it is 
usually exported to countries, such as China and India, which pay 
premium prices for the fiber. The stakeholders added that the constant 
supply of UAA mail available through USPS could be used to increase the 
domestic supply of recycled fiber. Such a supply increase could 
potentially decrease the cost of using recycled paper products which, 
in turn, could encourage their increased use.[Footnote 67] One way for 
USPS to undertake this opportunity is to collaborate with the American 
Forest and Paper Association, which, according to association 
representatives, is eager to increase mail-related recycling.[Footnote 
68] Such a collaboration, they said, would contribute to the 
association's goal of recovering (i.e., preventing landfill disposal or 
incineration) 55 percent of paper consumed in the United States by 
2012. In addition, USPS could collaborate with members of its Greening 
the Mail Task Force to design and implement a plan to increase the 
supply of paper fiber available for recycling.[Footnote 69] USPS also 
could choose to explore, or expand, partnerships with local recyclers. 
One paper recycling company in New Jersey, for example, purchases and 
transports UAA mail from USPS facilities in Maryland, Pennsylvania, New 
Jersey, and elsewhere to manufacture recycled paper products, such as 
paper towels, toilet paper, facial tissue, and napkins. According to a 
company representative, because UAA mail is a critical feedstock for 
the company's production methods, the company would like to increase 
its supply of UAA mail as long as the cost of transporting UAA mail to 
the company does not become prohibitive. 

Fourth, numerous stakeholders in the environmental advocacy industry, 
suggested that USPS establish a special, discounted postal rate--or 
Green Rate--as a means of inducing mailers to adopt one or more 
environmentally preferable attributes in their mailpieces. According to 
these parties, for example, USPS could establish a special discount for 
mailers that use recycled and/or certified paper. Such a discount, they 
said, would help mailers offset the increased costs associated with 
using recycled paper and would provide an incentive for mailers to use 
certified paper.[Footnote 70] A Green Rate also could reward mailers 
who, among other practices, (1) use certain targeted marketing 
strategies, (2) can demonstrate measurable reductions in the amount of 
UAA mail they send, and (3) use mail materials efficiently. With 
respect to targeted marketing strategies, for example, a Green Rate 
could reward mailers who voluntarily participate in mail opt-out 
programs--such as the program offered by Catalog Choice[Footnote 71]-- 
and can demonstrate that they honor mail recipients' requests to be 
removed from their mailing listings.[Footnote 72] A Green Rate also 
could reward mailers who, over time, reduce the amount of UAA mail they 
send. Beginning in May 2009, USPS intends to use its Intelligent Mail 
Barcodes to establish large mailers' UAA mail rates (the baseline) and, 
over time, measure changes in the frequency of the mailers' UAA mail. 
While large mailers will be required to use the barcodes to receive 
worksharing rates for their mailings, USPS also could choose to use 
these data to reward mailers who meet a specified target for UAA mail 
reductions. In addition, if USPS chose to do so, it could reward 
mailers according to a "sliding scale," whereby mailers would receive 
larger discounts for greater UAA mail reductions.[Footnote 73] A final 
example of practices that could be considered for a Green Rate is the 
use of two-way reusable envelopes and other mailpieces that use 
materials efficiently. 

Finally, numerous stakeholders suggested that USPS, using its existing 
transportation network, initiate a mail take-back program to facilitate 
the recycling of discarded and unwanted mail in rural, sparsely 
populated areas that do not have access to municipal paper recycling. 
[Footnote 74] While the details of such a program would need to be 
developed, stakeholders suggested that USPS--possibly, in collaboration 
with others--could supply mail recipients in these locations with pre-
addressed packages to send their discarded mail either directly to a 
plant for recycling or, indirectly, to other facilities--including, 
possibly, USPS facilities--where the packages could be held for 
subsequent pick up and recycling. Conceptually, such a program 
resembles several existing take-back programs for used products--such 
as inkjet cartridges, digital cameras, and cellular phones--whereby the 
program sponsor (e.g., a manufacturer) supplies the consumer with a pre-
paid and pre-addressed envelope for returning used products through the 
U.S. mail. Stakeholders noted that USPS receives revenue for returning 
the products under the existing take-back programs and, depending on 
how such a program is funded, also could receive revenue under a take-
back program for mail. 

USPS Would Need to Assess Several Factors in Deciding Whether to Adopt 
the Opportunities: 

Each of the five stakeholder-identified opportunities appears to be 
consistent with (1) the agency's long-standing commitment to 
environmental leadership and (2) the Postmaster General's recently 
expressed commitment to minimize USPS' impact on every aspect of the 
environment and to act as a positive environmental influence in U.S. 
communities. However, based on our analysis, USPS would need to assess 
factors such as cost; feasibility, including logistical considerations; 
and mission compatibility in deciding whether to adopt the 
opportunities. 

Cost Considerations: 

Each of the five opportunities has overall cost considerations given 
their likely impact on staff and other resources that would be needed 
to, among other actions, develop plans, procedures, and agreements for 
implementing them. USPS also would need to identify the staff and 
offices responsible for successfully initiating and carrying out the 
opportunities, and provide training as appropriate. In addition, while 
the costs associated with implementing a program for recognizing mail- 
related recycling achievements are likely to be minimal (and more than 
offset by increases in USPS' revenues), the remaining four 
opportunities necessitate additional cost consideration. For example, 
two of the opportunities--increasing awareness about mail recycling and 
initiating a Green Rate--appear to have little likelihood of increasing 
the agency's revenue. Furthermore, the remaining two opportunities-- 
collaborating with parties interested in increasing the supply of paper 
fiber available for recycling and initiating a mail take-back program-
-may not generate sufficient revenues to cover their costs. Depending 
on the magnitude of variance between the expected costs and revenues, 
USPS may find implementing one or more of the opportunities 
unacceptable. This is, in part, because as we recently testified, USPS 
faces multiple short-and long-term pressures in improving its 
operational efficiency, increasing its revenues, and controlling its 
costs--some of which are increasing faster than the overall inflation 
rate.[Footnote 75] In addition, unlike in the past, USPS is now subject 
to an inflation-based cap on the prices it can charge for its goods and 
services. Specifically, the 2006 Postal Accountability and Enhancement 
Act includes an annual limitation on the average percentage changes in 
rates for each market-dominant mail class--such as First-Class Mail and 
Standard Mail--which is linked to the change in the Consumer Price 
Index for All Urban Customers.[Footnote 76] 

In addition to these overall cost considerations, three of the five 
opportunities have additional cost-related factors that USPS would need 
to assess prior to deciding whether to adopt them.[Footnote 77] First, 
while the cost of collaborating with other entities to increase 
recycling awareness among mail recipients and to encourage mail 
recipients to recycle their mail could be minimal, according to a USPS 
official, each of its recent nationwide promotional campaigns (which do 
not involve collaboration) cost USPS approximately $2.1 million. Such 
costs, however, may be overstated with respect to a recycling campaign 
because USPS could choose, in collaboration with others, to target only 
mail recipients in zip codes that do not have access to municipal paper 
recycling (about 14 percent of the U.S. population). Furthermore, USPS 
could elect to "piggyback" a recycling awareness message on another of 
its promotional mailings, which, by itself, would result in little 
additional cost. However, according to USPS officials, such a 
promotional campaign would necessitate the use of recycled paper to 
remain consistent with the agency's recycling awareness message. As 
previously stated, using recycled paper is more expensive than using 
virgin paper and, thus, would increase the cost of such a campaign. 

Second, because establishing a special discount to induce mailers to 
adopt more environmentally preferable business practices would--absent 
other actions--reduce USPS revenues,[Footnote 78] USPS would have to 
assess the overall affects of such a discount on its financial 
position. In addition, USPS would need to assess the specific cost 
implications associated with each environmentally preferable attribute 
it chooses to include in a Green Rate. For example, if USPS were to 
consider allowing mailers who, among other attributes, use certain mail 
targeting strategies to qualify for a Green Rate (e.g., participation 
in voluntary opt-out programs), USPS would need to assess whether, and 
to what extent, doing so would reduce its revenues. USPS also would 
need to assess the costs associated with, among other of its 
activities, defining a Green Rate (i.e., determining which 
environmentally preferable attributes mailers must use to qualify for 
the discount) and, to avoid potential abuse, ensuring that the 
mailpieces presented by mailers as "green" actually qualify for the 
discount. 

Finally, initiating a mail take-back program in locations that do not 
have access to municipal paper recycling could greatly increase USPS' 
costs and workload. The extent of these increases would depend on a 
variety of factors, including (1) the volume of additional mail 
generated by the program; (2) the characteristics, including the 
dimensions and weight, of the take-back packages that would require 
processing and delivery; (3) whether the packages would need to be 
manually processed;[Footnote 79] (4) the frequency with which each 
package needs to be handled; and (5) the distance the packages need to 
be transported.[Footnote 80] First, depending on the rate of program 
participation, the volume of mail requiring USPS processing and 
delivery could increase substantially. In addition, because the intent 
of such a program is for a mail recipient to combine all of the mail 
they discard during a given time frame into a single package, the 
package would greatly exceed the weight of typical mailpieces received 
by the recipient.[Footnote 81] Furthermore, because communities that do 
not have access to paper recycling are typically in rural, sparsely 
populated areas, the increased volume of larger and heavier mailpieces 
probably would travel long distances before reaching their final 
destination, thereby increasing USPS' transportation costs throughout 
the journey. The volume, weight, and size of these packages also could 
overwhelm USPS' service capacity in certain rural locations. Rural 
postal delivery service is typically carried out by USPS letter 
carriers using privately-owned vehicles that may not be capable of 
accommodating the increased volume, weight, and size of the take-back 
packages.[Footnote 82] Thus, USPS may incur costs for additional 
vehicles or changes in its operational arrangements with its rural 
postal carriers. Finally, the packages mailed by recipients would not 
be presorted and, depending on how the program is implemented, may not 
be barcoded--two factors that would require more costly, manual 
processing before delivery. 

Feasibility Considerations: 

Four of the five stakeholder-identified opportunities also have issues 
related to their feasibility, which USPS would need to assess prior to 
their adoption.[Footnote 83] For example, if USPS chose to implement a 
program for recognizing mail-related recycling achievements, such as an 
incentive program for facility-level managers and employees, it would 
first need to collect the data needed to do so. The two existing 
sources for USPS recycling data--the agency's evaluation tool for its 
areas and the budgetary line-item for its districts--do not include 
facility-level data. Furthermore, collecting this data may not be 
feasible due to staffing constraints and the large number (about 
37,000, according to USPS) of postal facilities nationwide. In light of 
this feasibility limitation, however, and given USPS' goal of earning 
$40 million in recycling revenue in fiscal year 2010 from its 
districts' efforts (approximately $500,000 per district), the agency 
could, instead, focus on recognizing the significant achievements of 
its district managers and employees. A district-level incentives 
program, however, has its own feasibility constraints. For example, to 
help ensure equity in such an incentives program, USPS would need to 
resolve several factors related to the program's successful 
implementation. Specifically, USPS likely would need to make 
adjustments for large, regional variations in the price paid for 
recyclable mail-related materials.[Footnote 84] If USPS did not 
consider these variations, an incentives program based solely on 
revenue generated from mail-related recycling would seriously 
disadvantage certain districts. One possibility for resolving this 
issue may be to structure an incentives program on other metrics, such 
as the total tonnage of material recycled or a district's savings in 
waste disposal costs, either in lieu of, or addition to, recycling 
revenues. However, such an action would introduce other issues related 
to the opportunity's feasibility because, according to USPS officials, 
USPS does not currently require its organizations, including its 
districts, to (1) report their recycling tonnage or savings from waste 
disposal costs[Footnote 85] or (2) collect and report their recycling 
data using consistent methods.[Footnote 86] The Manager of USPS' 
Environmental Policy and Programs organization told us that the agency 
intends to require its area managers to report information on their 
recycling tonnage, in addition to their recycling revenue and waste 
disposal costs, but at the conclusion of our review, USPS had not 
required these managers to do so. 

Second, if USPS chose to coordinate with parties, such as domestic 
recyclers, to increase the supply of fiber available for paper 
recycling, it would need to resolve a multitude of logistical 
considerations. For example, (1) Where will USPS store its mail-related 
materials for recycling? (2) Is sufficient storage available within 
USPS facilities? (3) Who will load the materials for delivery to the 
recycler? (4) Who will be responsible for transporting the materials 
and how will the deliveries be accomplished? and (5) Given space 
constraints, how often will the materials need to be transported, and 
to whom? Furthermore, to the extent that USPS facilities, vehicles, and 
other materials (e.g., crates and moveable carts) are used, the agency 
would need, among other actions, to develop a method for sharing its 
costs with recyclers and others who benefit directly from its efforts. 
If USPS were to undertake this opportunity with a goal of recycling 
domestically--as recommended by some stakeholders--USPS may also wish 
to explore arrangements to recoup a portion of any reduction in its 
revenues attributable to using domestic recyclers. If USPS did not use 
its staff or if sufficient and capable staff is not available to 
undertake these and other efforts, USPS could hire a third party to 
identify locations where this opportunity may be feasible to implement 
and, in such cases, act as USPS' intermediary in addressing these and 
other logistical considerations.[Footnote 87] 

Similarly, if USPS chose to establish a Green Rate, the agency would 
need to resolve a wide range of issues related to the feasibility of 
doing so. For example, USPS would need to assess whether a discount for 
mailpieces with certain environmental attributes is the appropriate 
mechanism for promoting environmentally preferable business practices. 
If USPS were to proceed, it would need to define the parameters of the 
discount and, to avoid abuse, determine how it would ensure that mail 
presented as "green" actually qualifies for the discount. Several 
stakeholders expressed particular concern about the feasibility of 
enforcing a Green Rate, indicating that such a task would be 
administratively difficult and, possibly, impossible to accomplish. 
Finally, to determine whether a Green Rate is feasible, USPS would need 
to (1) assess the impact of such a discount on its net revenues and 
existing postal rates; (2) determine whether, and to what extent, a 
Green Rate would affect its market-dominate products, which are subject 
to an annual inflation-based price cap; and (3) if the establishment of 
the discount resulted in the need to raise postal rates, evaluate 
whether USPS would be able to raise rates in accordance with the 
requirements in Postal Accountability and Enhancement Act. 

Finally, to initiate a mail take-back program, USPS would need to 
consider the logistics and overall feasibility of collecting and 
transporting the increased volumes of larger and heavier mailpieces 
through the mail stream. USPS, probably in collaboration with others, 
also would need to determine how the program would work--which likely 
would be a complex arrangement. For example, what classes of mail would 
the program cover? Who would supply the packages and postage needed to 
return the discarded mail? How would the appropriate postage be 
determined? Furthermore, where would the packages be sent, and to how 
many locations? In addition, to estimate its costs, USPS would need to 
develop, among other factors, a method for estimating (1) the number of 
mail recipients who would participate in the program and (2) the 
volume, size, and weight of their discarded mail take-back packages. 
While these considerations are numerous, the most serious question with 
respect to the program's feasibility is "Who will pay the substantial 
costs associated with implementing the program?" 

USPS has three options to cover the costs of a mail take-back program. 
First, USPS could explore increases in its postage rates for the 
applicable classes of mail--an action that mailing industry 
stakeholders would likely strongly oppose. Furthermore, it may not be 
feasible to raise these rates because of a limitation specified in the 
Postal Accountability and Enhancement Act. Second, while USPS could 
require mail recipients to pay the postage needed to cover the 
program's costs, such an action, in our view, would greatly diminish or 
eliminate public participation. As we reported in 2006, one key to 
increasing the volume of materials recycled is to offer financial 
incentives to increase recycling. Thus, a mail take-back program that 
departs from this premise is, in our view, unlikely to succeed. 
Finally, USPS could solicit funding from other parties, such as 
communities, federal and non-profit organizations, businesses, 
environmental organizations, Congress, and other interested parties. 
While USPS could explore this option, it is unclear whether other 
parties would find it in their best interest to fund such a program. 
[Footnote 88] 

Mission Compatibility Considerations: 

While each of these opportunities appears to be consistent with the 
agency's environmental commitments, including the Postmaster General's 
recent commitments to both minimize the agency's impact on every aspect 
of the environment and to act as a positive environmental influence in 
U.S. communities, it is unclear to what extent USPS views actions to 
fulfill these commitments as being compatible with its mission and 
strategic goals. Similarly, it is not clear whether, or to what extent, 
USPS would be willing to sacrifice revenue and/or incur additional 
costs to further its environmental commitments. 

In addition, two of the five stakeholder-identified opportunities--the 
establishment of a mail take-back program and a Green Rate for 
mailpieces that incorporate a variety of environmentally preferable 
attributes--would necessitate additional cost considerations. First, 
several mailing industry stakeholders told us that they strongly oppose 
a Green Rate, in part, because of mission compatibility concerns. 
According to these stakeholders, unlike worksharing rates that reward 
mailers for reducing USPS' costs, a Green Rate discount does not align 
with USPS' primary mission of delivering the mail. In addition, they 
said that market forces and mailer preferences--not the establishment 
of a Green Rate--should determine whether mailers choose to include 
environmentally preferable attributes in their mailpieces. Depending on 
how USPS chose to define a Green Rate, some specific aspects of the 
definition could cause additional mission compatibility concerns. For 
example, if the use of certified paper was included in a Green Rate, 
USPS lacks the expertise needed to evaluate the relative merits of the 
various--and controversial--certification programs.[Footnote 89] 
Likewise, if a Green Rate incorporated certain targeted marketing 
strategies, USPS could be drawn into a contentious debate about the 
relative merits of various opt-out programs, including voluntary 
programs administered by Catalog Choice and others.[Footnote 90] 

Finally, as discussed previously, establishing a mail take-back program 
likely would result in significant increases in the volume, size, and 
weight of packages moving through the mail stream. Such increases could 
overburden USPS' delivery networks and create delivery delays. Related 
to this, several stakeholders from USPS and the mailing industry told 
us that USPS' mission is to deliver the mail in a timely fashion--not 
to help mail recipients recycle their discarded and unwanted mail. 

Conclusions: 

USPS, the mailing industry, and others have developed a wide range of 
initiatives that, over time, could alleviate some concerns related to 
the perceived negative impact of mail on the environment. Several of 
the initiatives also have the potential to improve USPS' financial 
position--while also enhancing its environmental reputation in U.S. 
communities. However, it is not clear what level of trade-offs, 
including decreased revenue and/or increased costs, USPS would find 
acceptable to incur to further its commitments and reputation on 
environmental matters. 

While much is being done, USPS has numerous opportunities to enhance 
its mail-related recycling efforts. For example, while establishing 
goals should assist USPS in generating substantial additional mail- 
related recycling revenues, the agency has not established similar 
goals for reducing its costs associated with waste disposal. 
Consequently, its recycling goals do not reflect the full financial 
benefit attributable to mail-related recycling. In our view, revising 
USPS' recycling goals to include savings from lower waste disposal 
costs or adopting additional goals that reflect the full financial 
benefit attributable to mail-related recycling would help focus USPS 
employees on the need to achieve greater cost reductions--consistent 
with one of USPS' strategic goals. Related to this, while USPS intends 
to develop a plan to help it achieve its recycling goals, it is not 
clear whether this plan will (1) specify how progress toward its goals 
will be measured or (2) ensure that the data USPS will use to measure 
its progress are accurate, reliable, and collected using a consistent 
method. Furthermore, while USPS launched a pilot recycling program in 
New York City to, among other objectives, apply lessons learned to 
other postal facilities, it is unclear whether, and to what extent, 
USPS will require its facility managers to adopt these lessons where 
applicable, feasible, mission compatible, and appropriate in view of 
cost and other considerations. Finally, while these considerations are 
also applicable to the adoption of the five stakeholder-identified 
opportunities discussed in this report, each opportunity, at a minimum, 
provides thoughts and insights on activities that USPS might find-- 
after careful analysis--beneficial to adopt. 

Recommendations for Executive Action: 

To increase USPS' recycling of mail-related materials and increase the 
amount of mail with environmentally preferable attributes, we recommend 
that the Postmaster General direct the Manager of Environmental Policy 
and Programs and other parties, as appropriate, to take the following 
four actions: 

* Revise the agency's recycling goals to include savings from lower 
waste disposal costs or adopt additional goals that would reflect the 
full financial benefit attributable to mail-related recycling. 

* Ensure that the mail-related recycling plan it develops specifies, 
among other matters, how USPS will (1) measure progress toward its 
goals and (2) ensure that the data it uses for these measurements are 
accurate, reliable, and collected using a consistent method. 

* After completion of the New York City pilot, require facility 
managers at other facilities to adopt lessons learned, where 
applicable, feasible, mission compatible, and appropriate in view of 
cost and other considerations. 

* Assess the environmental benefits of the mail-related recycling 
opportunities identified by stakeholders in this report, and any 
others, and adopt those opportunities that are feasible, compatible 
with USPS' mission, and appropriate in view of cost and other 
considerations. 

Agency Comments and Our Evaluation: 

USPS provided its written comments on a draft of this report by letter 
dated May 2, 2008. These comments are summarized below and are 
included, in their entirety, as appendix VI to this report. USPS agreed 
with three of our four recommendations and stated that it had begun 
initiating actions to implement them. USPS also agreed, in principle, 
with our remaining recommendation to adopt applicable lessons learned 
from its New York City recycling pilot nationwide, where feasible, 
mission compatible, and appropriate in view of cost and other 
considerations. USPS stated, however, that it cannot require all of its 
facility managers to adopt these lessons since "not all lessons learned 
are applicable nationwide." We recognize that the pilot's lessons will 
not be applicable at every postal facility and, thus, clarified the 
recommendation to avoid confusion. 

We are sending this report to the congressional requestors and their 
staffs. We are also sending copies to the Postmaster General and other 
interested parties. We will make copies available to others upon 
request. In addition, the report will be available at no charge on the 
GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staffs have any questions regarding this report, please 
contact me at [email protected] or by telephone at (202) 512-2834. 
Contact points for our Office of Congressional Relations and Public 
Affairs may be found on the last page of this report. GAO staff that 
made key contributions to this report are listed in appendix VII. 

Signed by: 

Katherine A. Siggerud: 
Director, Physical Infrastructure Issues: 

[End of section] 

List of Congressional Committees: 

The Honorable Joseph I. Lieberman: 
Chairman: 
The Honorable Susan M. Collins: 
Ranking Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Thomas R. Carper: 
Chairman: 
The Honorable Tom Coburn, M.D. 
Ranking Member: 
Subcommittee on Federal Financial Management, Government Information, 
Federal Services, and International Security: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Henry A. Waxman: 
Chairman: 
The Honorable Tom Davis: 
Ranking Member: 
Committee on Oversight and Government Reform: 
House of Representatives: 

The Honorable Danny K. Davis: 
Chairman: 
The Honorable Kenny Marchant: 
Ranking Member: 
Subcommittee on Federal Workforce, Postal Service, and the District of 
Columbia: 
Committee on Oversight and Government Reform: 
House of Representatives: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Our objectives were to (1) describe the key, recent recycling 
accomplishments (initiatives) of USPS,[Footnote 91] the mailing 
industry, and other stakeholders and (2) identify additional recycling 
opportunities that USPS could choose to engage in (or influence mailers 
to undertake), including the factors that USPS would need to assess 
prior to adopting the opportunities. Such factors include costs to 
USPS; feasibility, such as logistical considerations; and compatibility 
with USPS' mission. 

To address our overall reporting objectives, we interviewed a wide 
range of USPS officials as well as representatives from about 40 
organizations (stakeholders) that have expertise in mail and paper 
recycling issues. For expertise in mail, we contacted numerous, major 
mailing industry associations which encompass the three major classes 
of mail that contain advertisements--First-Class, Standard, and 
Periodical. For expertise on environmental matters, we contacted 
organizations with positions on a wide range of environmental matters, 
including the waste generated from mail. For expertise in paper 
recycling issues, we contacted organizations that, among other matters, 
have an interest in increasing the amount of paper fiber available for 
recycling. During our interviews, we requested contact information for 
other relevant stakeholders and, as appropriate, contacted 
representatives from those organizations who agreed to speak with 
us.[Footnote 92] The stakeholders we interviewed are listed in table 2. 

Table 2: Stakeholders Interviewed: 

Catalog Choice; 
Conservatree; 
Co-op America; 
EcoEnvelopes; 
Environmental Defense; 
Forest Ethics; 
GreenDimes; 
McDonough Braungart Design Chemistry; 
National Envelope; 
Norm Thompson Outfitters; 
Pitney Bowes, Inc.; 
Rand Whitney Recycling; 
RR Donnelley; 
The Alliance of Non-Profit Mailers; 
The American Forest and Paper Association; 
The Association for Postal Commerce; 
The Bank of America Corporation; 
The Direct Marketing Association; 
The Direct Marketing Association Nonprofit Federation; 
The Envelope Manufacturers Association; 
The Forest Stewardship Council; 
The Fulfillment Management Association; 
The Greeting Card Association; 
The Institute for Local Self-Reliance; 
The Magazine Publishers of America; 
The Mail Moves America Coalition; 
The Mailers Council; 
The National Newspaper Association; 
The National Postal Policy Council; 
The National Recycling Coalition; 
The National Solid Wastes Management Association; 
The National Wildlife Federation; 
The Newspaper Association of America; 
The 100% Recycled Paperboard Alliance; 
The Saturation Mailers Coalition; 
Time, Inc.; 
United States Environmental Protection Agency; 
United States Office of the Federal Environmental Executive; 
United States Postal Service; 
Weyerhaeuser. 

Source: GAO. 

[End of table] 

In addition, to describe recent USPS initiatives, we (1) reviewed and 
analyzed relevant documents related to the initiatives; (2) toured 
various facilities engaged in recycling activities, including USPS 
facilities in Baltimore and Philadelphia, a paper recycling facility 
and a printing facility; and (3) attended meetings of the "Greening the 
Mail Task Force"--a committee of USPS, mailing industry, and other 
stakeholders whose mission is to identify and address environmental 
issues that relate to the mail. We also interviewed a wide range of 
officials in various USPS organizations, including Environmental Policy 
and Programs, Address Management, Product Development, Pricing and 
Classification, Marketing, Government Affairs, the Office of Inspector 
General, and the Memphis Category Management Center. In addition, we 
interviewed USPS staff involved in implementing the New York City 
pilot; facility managers and employees involved with recycling in 
Baltimore and Philadelphia facilities; and employees involved with the 
National Postal Forum and the Mailers' Technical Advisory Committee, 
among others. To determine recent initiatives of the mailing industry 
and others, we interviewed each of the stakeholder organizations listed 
above and reviewed and analyzed relevant documents related to the 
initiatives they identified. We selected key, recent initiatives 
undertaken by USPS, the mailing industry, and others based on our 
professional judgment. 

To identify additional mail-related recycling opportunities that USPS 
could choose to undertake, we solicited the views of representatives 
from the aforementioned stakeholders. We specifically inquired about 
opportunities to increase the recycling of mail and the amount of mail 
with environmentally preferable attributes.[Footnote 93] We reported on 
those opportunities that stakeholders cited more than twice and that 
were not currently being addressed by an ongoing USPS initiative. 
Finally, using our professional judgment, we analyzed pertinent 
factors, such as cost; feasibility, including logistical 
considerations; and compatibility with USPS' mission, that USPS would 
need to assess prior to adopting the opportunities. 

We discussed First-Class, Standard, and Periodical Mail with 
stakeholders; however, we primarily focused on Standard Mail because of 
(1) its increasing prominence in the mail stream; (2) its contribution 
to the municipal solid waste stream; (3) USPS' responsibility for 
discarding large volumes of UAA Standard Mail; and (4) the issues 
critics cite related to Standard Mail, which are reflected in numerous 
"Do Not Mail" state legislative initiatives and a recent online 
petition for a national Do Not Mail Registry. While other studies 
measure the environmental impact of mail using different measurements 
(e.g., the carbon footprint attributable to mail),[Footnote 94] this 
report focuses on the role recycling plays in eliminating mail and mail-
related materials from municipal solid waste, decreasing USPS' waste 
disposal costs, increasing USPS' revenue, and enhancing USPS' 
commitment to environmental leadership. 

We conducted this performance audit from April 2007 to June 2008 in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

[End of section] 

Appendix II: Other USPS Actions to Increase the Amount of Mail with 
Environmentally Preferable Attributes: 

In addition to the two multi-faceted initiatives discussed in the body 
of this report, USPS also has undertaken other actions to increase the 
amount of mail with environmentally preferable attributes. First, 
according to USPS officials, the agency uses 100 percent recycled 
paperboard in its Priority Mail and Express Mail packages and 
envelopes.[Footnote 95] In addition, these officials stated that the 
agency's marketing materials, such as postcards and brochures, 
typically contain at least 10 percent recycled paper. Finally, USPS 
recently approved a change in its mailing standards which allows 
mailers to use reusable mailpieces, such as "two-way" envelopes. Such 
envelopes enable mail recipients to either remove or cover the 
recipient's address in order to reveal a return address.[Footnote 96] 
Mailers that use two-way envelopes do not need to include a return 
envelope in their mailpieces, which reduces their paper use and costs. 

[End of section] 

Appendix III: Depiction of Various Mail-Related Recycling Logos: 

Figure 1: Mail-Related Recycling Logos: 

[See PDF for image] 

This figure contains mail-related recycling logos from the following 
organizations: 
Direct Marketing Association; 
Envelope Manufacturers Association; 
Magazine Publishers of America; 
Sustainable Forestry Initiative Program; 
Forest Stewardship Council; 
Recycling Magazines is Excellent (collaboration between Verso Paper, 
Time Inc., and the National Recycling Coalition). 

Sources: The Direct Marketing Association; Envelope Manufacturers 
Association; Magazine Publishers of America; Verso Paper, Time Inc., 
and the National Recycling Coalition; Sustainable Forestry Initiative, 
Inc.; Forest Stewardship Council. 

[End of figure] 

Figure 2: Logos Indicating Paper Products Contain Recycled Materials or 
Are Recyclable: 

[See PDF for image] 

This figure contains logos indicating paper products contain recycled 
materials or are recyclable, with the following associated text: 
Product contains recycled materials; 
Product is recyclable. 

Source: National Recycling Coalition. 

Note: These logos appear on many products, including mail, but are not 
specific to mail. 

[End of figure] 

[End of section] 

Appendix IV: Other Stakeholder Initiatives to Increase the Amount of 
Mail with Environmentally Preferable Attributes: 

While several initiatives have been taken by the Direct Marketing 
Association (DMA), other stakeholders in the mailing industry and 
environmental advocacy organizations also have initiatives underway to 
increase the amount of mail with environmentally preferable attributes. 
For example, the National Postal Forum--a non-profit educational 
corporation--sponsors an annual postal event and trade show with the 
same name. This forum, among other goals, provides USPS and mailing 
industry attendees with training, education, and opportunities to 
communicate with USPS officials on matters related to the mail. In 
2007, the forum included a series of workshops designed to educate 
mailers on USPS' tools for improving the accuracy of their mailing 
lists and reducing UAA mail volumes. The May 2008 forum featured more 
workshops on improving the accuracy of mailing lists, including a 
series of "Xtremely Green" workshops to address the environmental 
implications of the mail and ways to effectively communicate to mail 
recipients about environmental issues. 

A second stakeholder, the Mailers' Technical Advisory Committee, (1) 
shares technical information on matters of mutual interest related to 
mail-related products and services and (2) discusses ways to enhance 
the value of these products and services.[Footnote 97] The committee 
recently published two reports. The first report, issued in 2006, 
contained a list of best practices for accurately addressing mailpieces 
and recommended, among other matters, that mailers--prior to each 
mailing--update their mailing lists by using USPS' tools for improving 
address accuracy. We were unable to ascertain the extent to which 
mailers have adopted the report's recommendations. The second report, 
issued in 2007, (1) outlined a system by which USPS could certify the 
accuracy of mailing lists purchased by mailers and (2) described 
several scenarios in which such a system would reduce UAA mail. 
According to USPS, it intends to develop a list certification system by 
October 1, 2010. However, this time frame is contingent on the 
deployment of software upgrades related to its postal automated 
redirection system and the mailing industry's implementation of 
Intelligent Mail barcodes, expected in May 2009. 

Third, several parties within the environmental advocacy industry have 
undertaken initiatives to decrease the amount of unwanted mail received 
by mail recipients. For example, "41 Pounds" and "GreenDimes"--a non- 
profit and for-profit organization, respectively--were established in 
2006 to help mail recipients decline (i.e., opt-out of) many types of 
unwanted mail, including credit card and sweepstakes offers, insurance 
promotions, coupon booklets, and catalogs. These organizations 
accomplish this goal by, among other activities, (1) helping mail 
recipients register for DMA's Mail Preference Service and (2) directly 
contacting non-DMA mailers--who are not required to use this service-- 
to request them not to send mail solicitations to these mail 
recipients. 41 Pounds charges $41 for its services and, according to 
its Web site, donates one-third of this fee to community and 
environmental organizations. GreenDimes charges $20 for its services 
and, as of mid-March 2008, planted five trees for its services and an 
additional tree for every catalog that a member (mail recipient) 
declined (up to five additional trees). In addition, Catalog Choice--a 
non-profit program sponsored by the Ecology Center and endorsed by the 
National Wildlife Federation and the Natural Resources Defense Council-
-offers a free service that allows consumers to stop receiving unwanted 
catalogs. Consumers can search for catalogs on the Catalog Choice Web 
site and, after providing their address information, opt-out of those 
they do not wish to receive.[Footnote 98] According to the 
organization's Web site, nearly 700,000 people had registered for its 
service, opting out of over 9 million catalogs as of March 31, 2008. 
[Footnote 99] 

Fourth, some parties within the envelope industry also have undertaken 
initiatives to increase the amount of mail with environmentally 
preferable attributes. For example, one major envelope manufacturer 
enables its customers to customize their envelopes with an assortment 
of environmentally preferable attributes, including recycled and 
certified paper. A company official estimated that 80 percent of his 
company's envelope sales include at least one environmentally 
preferable attribute. Another company designed reusable "two-way" 
envelopes that are made with at least 30 percent recycled paper. 

Fifth, some individual catalog mailers have undertaken their own 
efforts to incorporate environmentally preferable attributes in their 
mailpieces. In 2007, Forest Ethics--an environmental non-profit 
organization that, among other activities, encourages catalog companies 
to improve their environmental practices--surveyed the catalog industry 
and reported that nine major catalog mailers had attained its highest 
environmental rating by, among other actions, reducing the quantity of 
paper they use and using certified and recycled paper. Another catalog 
mailer partnered with Environmental Defense in 2001 and began using 
paper with 10 percent recycled paper. This company also offers mail 
recipients a "frequency opt-out" option that enables mail recipients to 
choose how often they wish to receive the company's catalog. 

Finally, to increase the prevalence of environmentally preferable 
attributes in magazines, a non-profit organization called Co-op America 
created the "Magazine PAPER Project."[Footnote 100] The project helps 
magazines change their business practices to better protect the 
environment by, among other actions, educating magazine publishers 
about the environmental consequences associated with the paper they use 
and working with publishers to help them adopt environmentally 
preferable practices, such as the use of recycled or certified 
paper.[Footnote 101] A representative of Co-op America estimated that 
the percentage of magazines using recycled paper is extremely 
low.[Footnote 102] According to the representative, convincing magazine 
officials to use recycled or certified paper is difficult, due, in 
part, to (1) confusion regarding the environmental benefits of using 
these products, (2) the higher cost of recycled paper, (3) the 
availability of recycled paper, and (4) the perception among many 
magazine companies that using recycled paper will adversely affect the 
appearance of their products. 

[End of section] 

Appendix V: DMA's List of 15 Environmentally Preferable Business 
Practices: 

As discussed in the body of this report, DMA developed a list of 15 
environmentally preferable business practices--the "Green 15." While 
adoption of these 15 practices is mostly voluntary, in June 2008, DMA 
intends to establish goals and timetables for measuring its members' 
success in implementing these practices, which, according to DMA 
officials, could lead to future DMA requirements. Overall, the Green 15 
consists of five mailer business practices: paper procurement and use, 
mailing list accuracy and data management, mail design and production, 
packaging, and recycling and pollution reduction. A description of the 
specific practices related to each of the five overall business 
practices follows: 

Paper procurement and use - Mailers should: 

1. Encourage paper suppliers to increase their wood purchases from 
recognized forest certification programs; 

2. Require paper suppliers to commit to implementing sustainable 
forestry practices that (a) protect forest ecosystems and biodiversity 
and (b) provide wood and paper products that meet industry needs; 

3. Ask paper suppliers where their paper comes from before purchasing 
it, with the intent of avoiding paper from unsustainable or illegally 
managed forests; 

4. Require paper suppliers to document that they do not produce or sell 
paper from illegally harvested or stolen wood; and; 

5. Evaluate the paper used for advertising, product packaging, and 
internal consumption in order to identify opportunities to increase 
their environmentally preferable attributes. 

Mailing list accuracy and data management - Mailers should: 

6. Comply with DMA guidelines for list management,[Footnote 103] such 
as: 

a. maintaining lists of consumers who do not wish to receive their mail 
solicitations; 

b. updating their mailing lists against the Mail Preference Service 
database; 

c. including--on every direct mail solicitation they send--an option 
for mail recipients to opt-out of receiving all direct mail 
solicitations from that member, regardless of whether a business 
relationship has been previously established; 

7. Use tools developed by USPS or other parties to improve the accuracy 
of their mailing lists; and: 

8. Apply predictive targeted marketing models to reduce unwanted mail, 
where appropriate. [Footnote 104] 

Mail design and production - Mailers should: 

9. Review their direct mail solicitations and other printed marketing 
material to determine whether, for example, smaller or lighter designs 
(that use less paper) are appropriate; and: 

10. Test and use production methods that reduce waste. 

Packaging - Mailers should: 

11. Encourage their packaging suppliers to submit price quotes for 
environmentally preferable packaging alternatives, in addition to 
approved or existing packaging specifications. 

Recycling and pollution reduction - Mailers should: 

12. Purchase office paper and packaging materials that are made from 
recycled paper, where appropriate; 

13. Integrate the use of electronic communications (e.g., e-mail, 
internet, and intranet) for both internal and external communications; 

14. Ensure that all environmental labeling is clear, honest, and 
complete; and; 

15. Participate in DMA's "Recycle Please" campaign and/or other 
recycling campaigns in order to demonstrate that their company or 
organization has a program to encourage recycling. 

[End of section] 

Appendix VI: Comments from USPS: 

Deborah Giannoni-Jackson: 
United States Postal Service: 
Employee Resource Management: 
475 L'Enfant Plaza, SW, Room 9840: 
Washington, DC 20260-4200: 
Fax: 202-268-3803: 
[hyperlink, http://www.usps.com] 

May 2, 2008: 

Ms. Katherine A. Siggerud: 
Director, Physical Infrastructure Issues: 
United States Government Accountability Office: 
Washington, DC 20548-0001: 

Dear Ms. Siggerud: 

Thank you for providing the U.S. Postal Service with the opportunity to 
review and comment on the draft report titled U.S. Postal Service: Mail-
Related Recycling Initiatives and Possible Opportunities for 
Improvement, (GAO-08-599). 

The Postal Service prides itself as a recognized federal leader in 
environmental stewardship. Over the past 10 years we have received 39 
White House Closing the Circle Awards and we continue to develop new 
and innovative strategies to help protect the environment. We have 
implemented a number of programs that reduce, reuse, recycle and 
rethink our use of resources that impact the environment. As such the 
Postal Service concurs with GAO's recommendations 1, 2 and 4 and we 
have already begun actions to implement those objectives. On 
recommendation 3, we agree in principle with this recommendation but 
not all lessons learned are applicable nationwide and therefore cannot 
be required of all managers. 

Recommendation 1 - Revise the agency's recycling goals to include 
savings from lower waste disposal costs or adopt additional goals that 
would reflect the full financial benefit attributable to mail-related 
recycling. 

Postal senior management has communicated recycling revenue improvement 
and solid waste disposal cost reduction goals for the next three years 
to the Vice Presidents, Area Operations. Monthly reporting on recycling 
revenue has been initiated and similar waste cost reduction data 
reporting is being developed. Fiscal Year 2009 area objectives for 
recycling are being reviewed to include solid waste cost reduction. 
These revised recycling revenue/solid waste disposal cost reduction 
objectives will be included in our national recycling plan that 
supports the Postal Service's Strategic Transformation Plan. 

Recommendation 2 - Ensure that the mail-related recycling plan it 
develops specifies, among other matters, how USPS will (1) measure 
progress toward its goals and (2) ensure that the data it uses for 
these measurements are accurate, reliable, and collected using a 
consistent method. 

The Postal Service currently tracks recycling revenue data from the 
organization's Enterprise Data Warehouse (EDW), which provides 
standardized, consistent and reliable information. The EDW also is 
expected to provide the same level of standardized data for solid waste 
disposal cost reduction. Each month, Environmental Policy and Programs 
reports to Areas and other USPS functions regarding recycling, 
including comparative data to other operating units and to same period 
last year (SPLY). The Postal Service also is improving its data 
collection/analysis ability for solid waste activities as part of its 
upgrade of the Environmental Management Information System (WebEMIS) in
Fiscal Year 2008. The Postal Service also is leveraging its 
participation in the Environmental Protection Agency's (EPA) Waste Wise 
program to provide accurate, reliable recycling and solid waste 
disposal information from an independent source. 

Recommendation 3 - After completion of the New York City pilot, require 
managers to adopt applicable "lessons learned" nationwide, where 
feasible, mission compatible, and appropriate in view of cost and other 
considerations. 

Throughout Fiscal Year 2008, the Postal Service has developed and 
provided training, messaging, policy and on-site and analytical support 
to share best management practices and other "lessons learned" from 
various USPS recycling programs, including San Diego, Houston, 
Connecticut, Alabama, Northern Virginia and Dallas. This training 
included recycling training at the national meeting of USPS 
environmental employees in November 2007 and a two-day training course 
for Area Recycling Coordinators in December 2007. Since January 2008, 
Environmental Policy and Programs has conducted monthly telecons with 
each Area Recycling Coordinator and the Area Manager, Environmental 
Programs, about the progress, roadblocks and prospective solutions to 
improve recycling revenue. A Management Instruction on Recycling and a 
Recycling Guide have been written and will be distributed later this 
year. Moreover, Environmental Policy and Programs has funded a detail 
to provide on-site support for New York City and other districts to 
revitalize their recycling programs. Lessons learned from New York and 
other revitalization efforts have been and will continue to be shared 
with other districts and areas. 

Recommendation 4 - Assess the environmental benefits of the mail-
related recycling opportunities identified by stakeholders in this 
report, and any others, and adopt those opportunities that are 
feasible, compatible with USPS' mission, and appropriate in view of 
cost and other considerations. 

The Postal Service continues to engage customers, mailers, mailing 
industry associations, suppliers, regulators, non-governmental 
organizations and other stakeholders regarding mail-related recycling 
activities. This dialogue includes the continuing work of the "Greening 
the Mail" Task Force, interactions with stakeholders at the National 
Postal Forum and in various ongoing dialogues within and outside the 
organization. 

If you or your staff wish to discuss any of these comments further, I 
am available at your convenience. 

Sincerely, 

Signed by: 

[Illegible] for: 
Deborah Giannoni-Jackson: 

[End of section] 

Appendix VII: GAO Contact and Staff Acknowledgments: 

GAO Contacts: 

Katherine A. Siggerud (202) 512-2834 or [email protected]: 

Staff Acknowledgments: 

In addition to the individual named above, Kathleen Turner, Assistant 
Director; Samer Abbas; Kathleen Gilhooly; Jeff Jensen; Joshua Ormond; 
Daniel Paepke; Stephanie Purcell; and Erin Roosa made key contributions 
to this report. 

[End of section] 

Footnotes: 

[1] Approximately 6 percent of all Standard Mail was UAA in 2004. USPS 
returns a small portion of UAA Standard Mail annually to mailers, at 
their request, and discards the remainder. 

[2] Recycling also helps reduce the incidence of water and air 
pollution and helps lower greenhouse gas emissions, among other 
benefits. Furthermore, manufacturing paper from recycled paper fiber 
may require less electricity, fuel, and water. 

[3] In addition, Forest Ethics, an environmental non-profit 
organization, recently initiated an online petition for a national Do 
Not Mail Registry. 

[4] Because many of USPS' mail-related recycling efforts are in the 
early stages of their implementation, we discuss these efforts as 
"initiatives," rather than as "accomplishments." 

[5] GAO, Postal Service and Mailing Industry Mail-Related Recycling: 
Accomplishments and Postal Opportunities-Interim Results, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-08-348R] (Washington, D.C.: Dec. 
20, 2007). 

[6] Mail-related materials include UAA mail, mail discarded in USPS 
facilities, and other materials related to mail such as plastic 
wrappings and cardboard. 

[7] Several forest certification programs exist. The programs are 
intended to recognize and promote environmentally preferable forestry 
management practices. 

[8] GAO, Postal Reform Law: Early Transition Is Promising, but 
Challenges to Successful Implementation Remain, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-08-503T] (Washington, D.C.: Feb. 
28, 2008). 

[9] Specifically, the 2006 Postal Accountability and Enhancement Act 
includes an annual limitation on the average percentage changes in 
rates for each market-dominant mail class--such as First-Class Mail and 
Standard Mail--which is linked to the change in the Consumer Price 
Index for All Urban Customers. The act includes exceptions to this 
inflation-based limitation, but USPS cannot raise postage rates beyond 
its legal authority. 

[10] Pub. L. No. 109-435 (Dec. 20, 2006). 

[11] Congress reimburses USPS for providing free or reduced postage 
rates to certain groups, such as the blind and overseas voters. For 
fiscal year 2008, Congress appropriated $118 million to USPS for these 
purposes. 

[12] The Mailing Industry Task Force, Seizing Opportunity: The Report 
of the 2001 Mailing Industry Task Force, October 2001. This task force 
includes chief executives of 11 leading mailing industry companies and 
the Deputy Postmaster General of USPS. 

[13] While USPS generally does not forward UAA Standard Mail to the 
addressee, mailers can pay USPS an additional fee to have this mail 
returned to them. 

[14] Direct mail refers to advertisements sent to recipients through 
the mail. 

[15] USPS operates two First-Class Mail recovery centers in St. Paul, 
Minnesota, and Atlanta, Georgia. These facilities are responsible for 
the final disposition of First-Class UAA mail. 

[16] Christensen Associates, Volumes, Characteristics, and Costs of 
Processing Undeliverable-As-Addressed Mail and Personal-Knowledge 
Required Mail (Madison, WI: March 2006). 

[17] In the past, some mail components, such as transparent envelope 
address windows and certain pressure-adhesive stamps, were difficult to 
recycle. However, according to USPS officials and other stakeholders, 
concerns about the recyclabilty of mail have generally been addressed. 

[18] The National Task Force on Greening the Mail, Recommendations of 
the National Task Force on Greening the Mail, January 1999. 

[19] The communities that do not have access to paper recycling 
programs generally are located in sparsely populated, rural areas. 

[20] GAO, Recycling: Additional Efforts Could Increase Municipal 
Recycling, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-37] 
(Washington, D.C.: Dec. 29, 2006). 

[21] As previously discussed, USPS treats UAA Standard Mail as waste 
when it cannot be delivered. 

[22] We adopted these environmentally preferable attributes for our 
reporting purposes. 

[23] For management purposes, USPS divides the country into nine 
geographic areas. Each area is comprised of districts, and there are 82 
districts nationwide. 

[24] USPS' Strategic Transformation Plan 2006-2010 lists four strategic 
goals: generate additional revenue; reduce costs; achieve results with 
a customer-focused, performance-based culture; and improve service. 

[25] Specifically, according to documentation supplied by USPS, in 
fiscal year 2006, the Processing and Distribution Centers in Boston, 
Massachusetts, and Carol Stream, Illinois, did not record waste 
disposal cost savings, while the Processing and Distribution Center in 
Portland, Oregon, combined recycling revenues and waste disposal cost 
savings in a single figure. Similar reporting inconsistencies exist at 
the district-and area-levels, according to USPS officials. 

[26] December 2007 update to USPS' Strategic Transformation Plan for 
2006-2010. 

[27] Integrated Waste Management, July 2007, Management Instruction EL- 
890-2007-5. 

[28] In September 2007, USPS also published guidance for implementing 
the policy, including information on how to initiate successful mail- 
related recycling programs at postal facilities entitled Implementation 
Guide for Managers: District Recycling Programs, September 2007. 

[29] Recycling of Discarded Mail and Undeliverable Bulk Business Mail, 
September 1995, Management Instruction AS-550-95-14. 

[30] Previously, USPS managed these contracts at the Memphis Center and 
three other similar centers located in California, Illinois, and 
Connecticut, according to USPS officials. 

[31] According to USPS officials, managers at small facilities still 
can enter into separate contracts for their facilities, if the 
contracts are cost-effective and valued at less than $2,500. 

[32] GAO, Postal Service: Progress in Implementing Supply Chain 
Management Initiatives, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-04-540] (Washington, D.C.: May 17, 2004). 

[33] USPS received a White House "Closing the Circle" award in 2007 for 
its use of Total Solid Waste Management contracts. These awards 
recognize outstanding federal achievements in a variety of 
environmental areas, including waste prevention, recycling, purchasing 
environmentally-preferable products, environmental management, 
sustainable buildings, disposal of electronics, and reduced fuel usage. 

[34] For example, after a USPS vehicle is loaded with mail at a mail 
processing and distribution center and transports the mail to local 
USPS facilities (e.g., post offices), the vehicle returns to the 
processing and distribution center. Instead of returning empty, or 
partially empty, however, the vehicle is loaded with UAA mail and other 
mail-related recycling materials, which have been collected and stored 
at local USPS facilities. The use of backhauling as a means to 
transport items and materials between postal facilities is not new. 
Rather, USPS has historically used backhauling to transport other 
items, such as mail processing equipment, between facilities. 

[35] New York City was chosen as the pilot site, in part, because of 
its complex delivery and operational network. USPS officials stated 
that if a mail-related recycling program can be successfully 
implemented in New York City, similar recycling programs probably could 
be implemented at postal facilities elsewhere. 

[36] New York City is comprised of five boroughs--Brooklyn, the Bronx, 
Manhattan, Staten Island, and Queens. References to "New York City" 
refer to all five boroughs, unless a particular borough is specified. 

[37] For perspective, if New York City had generated $1.3 million in 
recycling revenues in fiscal year 2007, it would have increased USPS' 
nationwide recycling revenues of $7.5 million by approximately 17 
percent that year. 

[38] As noted previously, USPS has nine areas and 82 districts. 
Facility managers report to district managers who, in turn, report to 
area managers. 

[39] The tool collects, among other information, data on revenues 
generated from recycling mail-related materials and other items. Such 
revenues include those generated from the sale of wastepaper, twine, 
and dead mail. Dead mail includes UAA mail and other mail-related 
materials. 

[40] The process of improving the accuracy of addresses that comprise 
mailing lists is often referred to as "address hygiene." 

[41] Worksharing rates are discounts that USPS provides to mailers who 
perform certain activities that avoid costs that USPS would otherwise 
incur. Worksharing activities include, among other things, having 
mailers (1) update and accurately format their addresses; (2) barcode 
and prepare mail so that it can be sorted by USPS' automated equipment, 
which reduces manual and other handling of mail; and (3) presort mail, 
such as by zip code or specific delivery location, to reduce the number 
of times USPS must sort the mail before delivery to a mail recipient. 

[42] Prior to the requirement's change, First-Class mailers had to 
update their mailing lists 185 days prior to each of their mailings. 

[43] In December 2007, USPS' Board of Governors approved a negotiated 
service agreement between USPS and the Bank of America. The agreement-
-the first ever performance-based negotiated service agreement-- 
requires the Bank of America to, among other actions, reduce its volume 
of UAA mail in exchange for worksharing rates. USPS has entered into 
other negotiated service agreements, but the previous agreements 
provided mailers with postage rate discounts based on (1) the volume of 
mail they sent and (2) the amount of work that USPS avoided, not on 
reductions in the mailers' UAA mail volumes. 

[44] DMA is the main trade association for the direct mail industry. It 
represents, among others, about 2,700 large mailers who send, 
collectively, about 80 percent of all Standard Mail. The Envelope 
Manufacturers Association represents envelope manufacturers, includes 
approximately 147 organizations, and collectively produces about 80 
percent of U.S. envelopes and about 60 percent of envelopes worldwide. 
The Magazine Publishers of America is the main trade association for 
the magazine industry and represents approximately 240 companies, which 
publish over 1,400 magazine titles. 

[45] The volume of materials recycled varies for different types of 
mail. For example, according to industry stakeholders, Americans 
recycled about 36 percent of the catalogs and direct mail delivered to 
their residences in 2005, while prior studies (pre-2006) indicate that 
about 20 percent of magazines delivered to U.S. homes were recycled. 

[46] While association officials provided us with data on their 
members' participation rates, officials from two of the three 
associations believe their data underestimate the extent of 
participation in their programs. For example, DMA stated that its 
recycling awareness campaign is targeted toward DMA members that market 
to consumers. Thus, according to DMA, 4 percent of these members 
participate in the association's "Recycle Please" program. In addition, 
DMA noted that some DMA members "operate multiple brands, so the 
Recycle Please logo could be widely disseminated across many brands by 
a single parent company." Furthermore, a magazine association official 
stated that at least 16 percent of its members' magazine titles use the 
"Please Recycle" logo and that these titles account for about 54 
percent of the total number (copies) of magazines currently in 
circulation. 

[47] The National Recycling Coalition is a non-profit organization that 
focuses on recycling and waste prevention nationwide. 

[48] The chasing arrows logo can indicate, for example, that a product 
is recyclable, made from 100 percent recycled content, or made 
partially from recycled content. 

[49] The logo used in the "Recycling Magazines is Excellent" project is 
depicted in figure 1 of appendix III. 

[50] The Prince George's County pilot also includes the Washington, 
D.C., metropolitan area. 

[51] One of our objectives is to report on the recent key initiatives 
undertaken by USPS, the mailing industry, and other stakeholders. While 
the Mail Preference Service is not new, we discuss it in this report 
because, historically, it was the main tool available to mail 
recipients who wanted to decrease the amount of unwanted mail they 
receive. 

[52] "Prospecting mail" is advertising mail that mailers send to mail 
recipients in an attempt to establish a business relationship (i.e., 
future business) with them. 

[53] Consumer requests to opt-out of receiving prospecting mail do not 
affect DMA member mailings to consumers when the member has already 
established a business relationship with the customer. Instead, these 
mailings will continue. Additionally, DMA members that have pre- 
existing relationships with consumers who have registered with the Mail 
Preference Service can continue to exchange these consumers' personal 
information with other companies for marketing purposes. 

[54] Until recently, DMA charged consumers a $1 fee, payable by credit 
card or check, to sign up for the Mail Preference Service--regardless 
of how the consumer signed up for the service. The $1 fee still applies 
to opt-out requests sent through the mail. However, DMA eliminated this 
fee in January 2008 for internet-based requests. While a valid credit 
card number is still required for authentication purposes, according to 
a DMA official, the association is testing different methods to 
authenticate consumer opt-out requests and no longer requires a credit 
card number for non-catalog internet-based requests. 

[55] A similar DMA service--the Deceased Do Not Contact List--enables 
family members to permanently remove a deceased individual from 
prospect mailing lists. The Deceased Do Not Contact list was created in 
response to concerns that mail addressed to deceased individuals (1) 
poses a risk of identity theft--particularly when the mailpiece 
contains sensitive information, such as an unsolicited credit card 
offer--and (2) distresses grieving family members. 

[56] To encourage members to adopt the 15 environmentally preferable 
practices, DMA developed a "Green 15 Toolkit," which contains, among 
other matters: (1) information on paper recycling, paper procurement, 
and the environmental impact of mail; (2) guidance on how members 
should benchmark their progress toward adopting environmentally 
preferable practices; (3) strategies to improve address accuracy and 
reduce UAA and unwanted mail; and (4) a "paper pledge" template that 
members can use to develop a paper procurement policy that considers 
environmentally preferable practices. 

[57] According to DMA officials, DMA intends to educate and encourage 
its members to use recycled and certified paper whenever feasible, but 
does not intend to specify which certification program its members 
should use. Instead, DMA specifies a list of available forest 
certification programs and allows its members to choose the program or 
programs that best suits their needs. 

[58] In other words, if a consumer contacts a company and asks to be 
removed from its future mailings, that consumer will no longer receive 
any mailpieces from the company. Should the consumer later place an 
order for a product with that company, the consumer will receive the 
product and any correspondence related to it (e.g., invoices and 
bills), but--under the terms of the program--would not receive other 
direct mail solicitations from the company. 

[59] Currently, members must comply with all of the program's 
requirements, except for the provision that every mail piece contain an 
option to opt-out of future direct mail solicitations from that member. 
DMA officials stated that the Association has delayed enforcement of 
this requirement to allow sufficient time for its members to redesign 
and test their mailpieces. 

[60] The Commitment to Consumer Choice program also allows DMA members 
to provide customers with a "frequency opt-out" option. When available, 
such an option would allow mail recipients to specify the frequency 
with which they wish to receive future mailings, such as catalogs, from 
a DMA member without opting out of all mailings from the member. 

[61] Although DMA's process for ensuring that its members comply with 
its requirements also is not a recent initiative, we nonetheless 
describe it to convey the method by which DMA officials said the 
association enforces its member requirements. 

[62] According to DMA officials, the association also randomly selects 
about 200 of its members annually for monitoring using a "secret 
shopper" program. According to these officials, the monitoring program 
helps to ensure that DMA members are complying with the association's 
requirements. 

[63] According to a DMA official, the Committee on Ethical Business 
Practices is comprised of approximately 15 DMA members, who meet once 
per month to resolve consumer complaints against DMA mailers. 

[64] As discussed in appendix I, we reported on those opportunities 
that stakeholders cited more than twice and that were not currently 
being addressed by an ongoing USPS initiative. 

[65] As discussed previously, these initiatives include DMA's "Recycle 
Please" program, the magazine and envelope associations' "Please 
Recycle" programs, the National Recycling Coalition's development of a 
recycling logo specific to mail, and the "Recycling Magazines is 
Excellent" program initiated by the National Recycling Coalition; Time, 
Inc.; and Verso Paper. 

[66] As noted previously, one of the Task Force's five subcommittees-- 
the subcommittee on "Education and Awareness on Sustainability and 
Value of the Mail"--intends to, among other goals, promote awareness 
that mail is recyclable. 

[67] Many mailers told us that using recycled paper is more expensive 
than using virgin paper (i.e., paper made from unrecycled fiber 
harvested directly from forests) for their mailings. 

[68] According to USPS officials, the agency recently invited 
representatives of the American Forest and Paper Association to 
participate on the Greening the Mail Task Force. 

[69] As previously noted, one of the Task Force's five subcommittees-- 
the subcommittee on "Recycling Collection of the Mail"--intends to, 
among other goals, increase mail recycling by implementing and 
supporting mail recycling initiatives in postal facilities, office 
buildings, and private residences. 

[70] As previously described, certified paper is produced from forests 
that are managed according to a variety of environmentally preferable 
practices. The two major forest certification programs in the U.S. are 
the Sustainable Forestry Initiativeï¿½ and the Forest Stewardship 
Council. The Sustainable Forestry Initiativeï¿½--formerly a part of the 
American Forest & Paper Association--is now an independent organization 
managed by the Sustainable Forestry Initiative, Inc. The logos for 
these certification programs are depicted in figure 1 of appendix III. 

[71] As previously discussed, mail opt-out programs enable mail 
recipients to decline to receive certain mail solicitations, such as 
credit card offers and catalogs, from direct mail marketing companies. 
One such program is Catalog Choice, which is a free service that allows 
mail recipients to opt-out of unwanted catalogs that they currently 
receive. For more information on Catalog Choice, see appendix IV. 

[72] As discussed, DMA allows mail recipients to opt-out of receiving 
certain mailings from its members. Because DMA members are required to 
honor those requests, it seems unlikely that such actions would qualify 
for a special postal discount. Therefore, if USPS were to develop a 
Green Rate related to the mailers' participation in opt-out programs, 
it would likely focus on programs in which mailer participation is 
voluntary. 

[73] The current performance-based Negotiated Service Agreement with 
Bank of America is structured in a similar fashion. 

[74] According to a 2005 survey conducted by the American Forest and 
Paper Association, 14 percent of the population (31 percent of U.S. 
communities) reside in these areas. 

[75] GAO, Postal Reform Law: Early Transition is Promising, but 
Challenges to Successful Implementation Remain, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-08-503T] (Washington, D.C.: Feb. 
28, 2008). 

[76] The Act includes exceptions to this inflation-based limitation, 
but USPS cannot raise postage rates beyond its legal authority. 

[77] We did not identify any additional cost considerations related to 
two of the five opportunities--implementing an incentives program and 
collaborating with others to increase the supply of paper fiber needed 
for recycling. 

[78] Generally speaking, if USPS chose to implement a Green Rate, its 
net revenues would decrease by the amount of the discount multiplied by 
the number of mailpieces that were mailed using the discount. Although 
the lower cost for postage could cause some mailers to increase the 
number of mailpieces they send, we believe that such an increase would 
be marginal and that it likely would not offset the lost revenues to 
USPS caused by a Green Rate. 

[79] Manual mail processing is far more costly than processing mail on 
USPS' automated equipment. 

[80] This distance includes both the mileage between (1) the mail 
recipient's residence and the recipient's local post office (i.e., the 
locations where the package presumably would be picked up and initially 
delivered) and (2) the local post office and the location of the 
package's destination. 

[81] Additional take-back packages would be needed if the amount of 
discarded mail exceeded the capacity of a single package. The 
additional packages also would be heavier than those of typical 
mailpieces. 

[82] As noted previously, such packages likely would be picked up at 
the mail recipient's address during the U.S. letter carriers' normal 
mail deliveries. 

[83] We did not identify any factors related to the feasibility of 
increasing recycling awareness among mail recipients. 

[84] For example, according to USPS documentation, a Processing and 
Distribution Center in Portland, Oregon, sold its UAA mail for $25 per 
ton in fiscal year 2006, whereas the Southeastern Pennsylvania 
Processing and Distribution Center was able to sell the same material 
for $105 per ton. 

[85] According to USPS documentation, in fiscal year 2006, three 
(Albany, New York; Southeastern Pennsylvania; and Carol Stream, 
Illinois) of the nine Processing and Distribution Centers USPS surveyed 
do not collect information on the amount of materials (tonnage) they 
recycle and two (Boston, Massachusetts; and Carol Stream, Illinois) do 
not collect data on savings from avoided waste disposal costs. 

[86] As discussed, according to both USPS officials and our analysis of 
USPS documentation some district facilities combine recycling revenues 
with waste disposal costs. Additionally, our analysis of USPS 
documentation indicates that in fiscal year 2006, at least one large 
district facility combined recycling revenues with waste savings 
attributable to recycling, which, together, comprise the full financial 
benefit of recycling. Similar reporting inconsistencies exist at the 
District and Area levels, according to USPS officials. 

[87] In New Jersey, for example, Rand Whitney serves as an intermediary 
between a paper-recycling company and 457 USPS facilities in 
Pennsylvania and, in return for its services, receives 25 percent of 
the full financial benefit generated under its contract. 

[88] While a mail take-back program is similar conceptually to several 
existing take-back programs for other used products (e.g., inkjet 
cartridges, digital cameras, and cellular phones), the critical 
difference is that for these programs, another party (not USPS) pays 
all of the costs--an action that the party presumably views as 
beneficial to its self-interest. 

[89] Evaluating the relative merits of the various certification 
programs likely would require expertise in environmental principles and 
practices associated with managing forests. 

[90] For example, DMA recently advised its members not to accept opt- 
out requests originating from Catalog Choice and other (non-DMA) 
programs. Appendix IV provides additional information on this matter. 

[91] Because many of USPS' mail-related recycling efforts are in the 
early stages of their implementation, we discuss these efforts as 
"initiatives," rather than as "accomplishments." 

[92] Despite several attempts, we were unable to obtain interviews with 
representatives from numerous organizations including the American 
Bankers Association; the American Catalog Mailers Association; the 
Center for a New American Dream; the Mailing & Fulfillment Service 
Association; the Major Mailers Association; the National Association of 
Presort Mailers; the Printing Industries of America; and the U.S. 
Conference of Mayors. 

[93] As described previously, these attributes include mail that (1) 
contains paper from recycled paper fiber (recycled paper); (2) uses 
paper from responsibly-managed forests (certified paper); (3) is 
designed to use materials efficiently, such as reusable "two-way" 
envelopes; (4) is accurately addressed for delivery; and (5) is 
targeted to mail recipients who may wish to receive it. 

[94] For example, USPS issued a study in 2007 that concluded that 
advertising mail has a positive overall environmental impact, in part, 
because it reduces the number of shopping trips consumers would 
otherwise make to purchase products. 

[95] USPS received a "Cradle to Cradle" certification from a consulting 
firm in 2007 for its Priority Mail and Express Mail packages and 
envelopes. The consulting firm--which helps clients create 
"ecologically intelligent products"--awards these certifications to 
parties that demonstrate an understanding of their products' 
environmental impact. 

[96] USPS officials stated that reusable mailpieces are not frequently 
used because mail recipients often inadvertently destroy the return 
mechanism when they first open the envelope. In addition, according to 
a USPS marketing official, USPS typically does not encourage customers 
to reuse its Priority Mail or Express Mail packaging and envelopes 
because doing so likely would decrease the image of these items and 
detract from USPS' brand name. 

[97] The committee is comprised of USPS officials, over 50 mailer 
associations, and a small number of other organizations in the mailing 
industry. 

[98] The Catalog Choice Web site includes links to hundreds of catalog 
company Web sites. Catalog Choice also plans to offer consumers the 
opportunity to "opt in" to catalogs they wish to receive. 

[99] The introduction of services offered by organizations such as 41 
Pounds, GreenDimes, and Catalog Choice has been contentious. In late 
2007, the Direct Marketing Association met with its members and advised 
them not to accept opt-out requests provided by these and other 
organizations unless they meet certain authentication and privacy 
requirements. According to DMA officials, the advice was offered, in 
part, to address concerns about whether opt-out requests submitted 
through these organizations truly originated from a mail recipient. DMA 
officials explained that, several years ago, one company registered its 
entire mailing list with DMA's Mail Preference Service, with the 
objective of ensuring that its customers would not receive mail from 
other direct marketers. A Catalog Choice official explained that his 
organization also has measures in place to detect fraudulent opt-out 
requests. Additionally, the official said that although DMA's Service 
offers consumers the opportunity to opt-out of catalogs, he believes 
the service provided by Catalog Choice is easier to use. 

[100] According to its Web site, Co-op America's mission is to harness 
economic power--the strength of consumers, investors, businesses, and 
the marketplace--to create a socially just and environmentally 
sustainable society. 

[101] While there are several forest certification programs, the 
Magazine PAPER Project only supports paper certified by the Forest 
Stewardship Council. 

[102] Specifically, out of approximately 18,000 distinct magazine 
titles in the United States, the official estimated that less than 1 
percent use recycled paper. His estimate is likely to understate the 
percentage of magazines that use recycled paper, however, because some 
magazines have low circulation rates and, consequently, are not known 
to Co-op America. 

[103] DMA requires its members to comply with its list management 
guidelines. Currently, this is the only required component of the Green 
15. 

[104] Predictive targeted models use customer data such as age, gender, 
and purchase history to forecast customer purchasing behaviors. 

[End of section] 

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